COMMISSIONER OF INCOME TAX WEST BENGAL Vs. ISTHMIAN STEAMSHIP

JUDGEMENT

(1.) :

(2.) THIS is an appeal from a Judgment of the High court at Calcutta in a reference under S. 66 (1), Indian Income-tax Act, 1922.

(3.) THE Income-tax Appellate tribunal did not accept the first ground but based its decision only on the second ground. In this appeal we are not concerned with the first ground, because, as has been pointed out by the learned chief justice in the order granting leave to appeal, the income-tax authorities appear to have accepted the view of the tribunal on the first point since they did not ask the tribunal to state a case giving rise to the contention which had found favour with the Appellate Assistant Commissioner but had been rejected by the tribunal.