( 1 ) THE relevant assessment year involved in this case is 1988-89. The question that has arisen has to be answered on the basis of the law, as it stood for the previous year relevant for the assessment year. The question raised in this case relates to the eligibility of deduction under section 32ab of the Income-tax Act, 1961. Having regard to section 32ab as it stood then whether the income derived under the head "income from business or profession" only would be eligible for deduction under section 32ab (l) (ii) or this deduction would be allowable on the income of the eligible business contemplated under sub-section (3) of section 32ab. In other words, whether this 20 per cent. income is to be allowed on the income of the eligible business contemplated under sub-section (3) of section 32ab irrespective of the fact that it might include income from sources other than income from business or profession. The Tribunal had held against the assessee that the income derived under the head "profits and gains of business or profession" only would be eligible following the decision in Northern India Theatre P. Ltd. , 56 ITD 42 (TM) and CIT v. Dinjoye Tea Estate (P.) Ltd.