Court : Income Tax Appellate Tribunal ITAT Madras
Reported in : (1995)54ITD701(Mad.)
1. Centered as they are on a common issue, these appeals by the assessee were heard together and are disposed of by a common order. The assessee's appeal relating to the assessment year 1979-80 is directed against the order dated 17-7-1985 of the AAC, A-Range, Madras ; while the remaining ten appeals are directed against the common order dated 27-1-1987 of the AAC, A-Range, Madras.2. The background data necessary for a proper appreciation of the issues involved in this case may be briefly noticed at the outset. The temple of Lord Venkateswara (Lord Srinivasa or Lord Balaji as He is variously called), situated on the Seven Hills, is a very ancient temple. Its origin is shrouded in the mists of antiquity. It was Shri Ramanujacharya (case 1017-1137 AD), the propounder of Visishtadvaita philosophy, who systematised the rites, rituals and routine - daily, occasional and annual -of the ancient temple. He entrusted the various tasks concerning the rites and rituals of the temple to various p...
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Madras
Reported in : (1995)54ITD680(Mad.)
1. This appeal by the assessee which is directed against the order of the CIT (Appeals) dated 8-8-1989 pertains to assessment year 1986-87 wherein he has held that manufacturing or processing is involved while applying metalock technique or processes and thereby section 3 5AB was applicable. The assessee has taken grounds to urge that the CIT (Appeals) erred in his decision and he ought to have allowed the technical know-how fees paid under section 37(1) of the Income-tax Act, 1961.2. The relevant facts are that the assessee is a company in which public are not substantially interested. The assessee is engaged in ship repairing. The assessment year involved is 1986-87 for which the accounting year ended on 31-3-1985. The assessee paid technical know-how fees of Rs. 1,58,202 to M/s. Metalock International Association Ltd., U.K. and claimed as a deduction under section 37(1).The Assessing Officer held that the case of the assessee fell under section 35AB inserted by the Finance Act, 198...
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