Court : Income Tax Appellate Tribunal ITAT Patna
Reported in : (1998)64ITD129(Pat.)
..... .7. apart from supporting the view taken by the learned accountant member, the learned departmental representative invited my attention to expln. 6 inserted in s. 271 of the act by direct tax laws (amendment) act, 1989, w.e.f. 1st april, 1989, which runs as under : "explanation 6. - where any adjustment is made in the income or loss declared in the ..... in consonance and conformity with the intent, purpose, object and spirit of the entire scheme of an enactment as a whole and not in a piecemeal and truncated manner divorced from and in isolation with the main, basic and fundamental provisions of a statute or an enactment. i do not wish to discuss in detail here the various decisions ..... 1st april, 1976 and the case, therefore, does not support the assessee.25. on the other hand, the decision of the kerala high court in the case of cit vs. indian sea foods (1976) 105 itr 708 (ker) has referred to the law after 1st april, 1976 and supports the department's stand [para 37 of the decision in (1994 .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Patna
Reported in : (1993)45ITD101(Pat.)
..... their book income tax law (3rd edition), at page 605, have opined as under : a new clause (bb) has been inserted in section 13(1) by the taxation laws (amendment) act, 1975, with effect from april 1, 1977. as has been discussed in 'the restrictive words qualify only the fourth limb', at page 573, ante, the ban of carrying on ..... only the last head of charitable purpose and not the earlier three heads. he further took into consideration the newly inserted section 13(1)(bb) of the act inserted by the taxation laws (amendment) act, 1975, with effect from april 1, 1977, and which remained operative till march 31, 1983.section 13(1)(bb), as it stood at the relevant time ..... society was exempt under section 11. on a reference, the high court held that the society's object was one of general public utility and relying upon the decision in indian chamber of commerce v. cit [1975] 101 itr 796 (sc), it was held that its advancement was linked or connected with an activity for profit and, therefore, did .....
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