Separate assessees principle preserves section 84 relief for a firm even where partners already received the benefit.

A registered firm and its partners are separate assessees for income-tax purposes, so statutory relief attaches to the assessee who independently satisfies the conditions of the provision. Relief granted to partners in their individual assessments does not, by itself, bar the firm from claiming the same benefit in its own assessment. Earlier authorities under the 1922 Act and the 1961 Act supported this construction, and the Board's circular ing the earlier High Court view reinforced it. On that basis, the firm remained entitled to relief under section 84 notwithstanding the partners' separate allowances.

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Issues: Whether a registered firm was entitled to relief under section 84 of the Income-tax Act, 1961, in its own assessment when similar relief had already been granted to its partners in their individual assessments.

Analysis: The governing principle applied was that the firm and its partners are separate assessees and the statutory relief under section 84 is available to the assessee to whom it applies. Prior authorities under both the 1922 Act and the 1961 Act had held that the allowance of exemption or relief in the partners' assessments does not by itself justify denial of the same statutory benefit to the firm if the firm independently satisfies the conditions. The Board's circular accepting the earlier High Court view reinforced this construction of the provision.

Conclusion: The firm was entitled to relief under section 84 notwithstanding that similar relief had been allowed to the partners.

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