- (1.) THE controversy here concerns the amount collected as royalty on the sale of bricks by the assessee, a partnership firm, carrying on business of manufacture and sale of bricks, the assessment year in question being 1972-73.
(2.) IT was during the three earlier assessment years, namely, 1967-68, 1968-69 and 1969-70 that Rs. 1,075, Rs. 2,879 and Rs. 7,472, respectively, were received by the assessee as royalty, the total amount collected during these three years being Rs. 12,697.
(3.) THE amounts collected as royalty were shown under a separate and distinct head in the balance-sheet, but they were neither treated as a trading receipt nor was any deduction claimed in respect of them.;