CANARA INDUSTRIAL AND BANKING SYNDICATE LIMITED Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) IN this reference, under section 66(1) of the INdian INcome-tax Act, 1922, the INcome-tax Appellate Tribunal (Bombay Bench "B") has referred two questions of law our opinion. They are :

(2.) THE facts of the case as disclosed by the statement of the case submitted by the Tribunal to the extent relevant for our present purpose reads as follows :

(3.) SECTION 60(1) of the Indian Income-tax Act empowered the Governor-General in Council (subsequently changed to the Central Government) to make exemptions, etc., and the material portion of it (with verbal changes made subsequently) stands as follows :