COMMISSIONER OF INCOME TAX Vs. INDIA RECONSTRUCTION CORPORATION LIMITED

JUDGEMENT

(1.) IN compliance with the direction of this court made under section 66(2) of the INdian INcome-tax Act of 1922 (hereinafter referred to as the Act), a statement of the case and the following question of law has been referred to this court by the INcome-tax Appellate Tribunal, Allahabad Bench, Allahabad (hereinafter referred to as the Tribunal) :

(2.) THE instant reference has been made at the instance of the department. THE assessee is a limited liability company styled as M/s. India Reconstruction Corporation Ltd., Kanpur (hereinafter referred to as the assessee).

(3.) THE assessee filed an appeal before the Appellate Assistant Commissioner on the ground that the sum of Rs. 20,762 should not have been and could not be assessed as income from business. THE Appellate Assistant Commissioner dismissed the appeal and confirmed the order of the Income-tax Officer.