N.N. Mathur, J.-The issue arising for decision in these two special appeals is whether the additional conveyance allowance paid by the Life Insurance Corporation of India (in short, “the LIC”) to its

Development Officers in terms of the norms of the business fetched by them as per circular dated March 3, 1987, issued by the Life Insurance Corporation is exempt under Section 10(14) of the Income-tax Act, 1961, hereinafter referred to as “the Act of 1961”, as special allowance or not?

2. Since the learned single judge has disposed of the writ petitions by a brief order having found the controversy covered by an earlier decision of this court rendered in CIT vs. Shiv Raj Bhatia [1997] 227 ITR 7, a brief resume of facts would be necessary for focussing the issue involved in these appeals.

3. The appellant, Shivraj Bhatia, Development Officer with the Life Insurance Corporation of India, during the assessment proceedings for the year 1986-87, claimed 40 per cent. deduction (Rs. 27,282) from a sum of Rs. 68, 206 received as an incentive bonus from the Life Insurance Corporation. The Assessing Officer found that the incentive bonus being part of the salary, the deduction as claime