Suhas Chandra Sen, J. - (1.) In this case, we are concerned with the assessment year 1964-65, for which the relevant accounting year is the calendar year 1963.
(2.) The facts of this case are as follows : For this assessment year the assessee-company amongst other claims contended before the ITO that the dividend from foreign companies should be assessed not on the gross amount of the dividends (hereinafter referred to as " the gross dividend ") but on the gross amount of the dividends less tax deducted therefrom in the foreign countries (hereinafter referred to as " the net dividends"). Another claim of the assessee was that the amount due from Chingrihata Bone Mills (P.) Ltd. amounting to Rs. 2,53,484 and interest thereon amounting to Rs. 49,132, which was written off, should be allowed as a deduction in computing the business income. The ITO, however, did not accept either of these two claims.
(3.) The asseessee-company was aggrieved with the assessment order and, therefore, went up in appeal before the AAC. The AAC together with other reliefs accepted the claim of the assesseee-company on both of these points.;