https://www.taxtmi.com/caselaws?id=289474 In a section 66 reference, a new factual or legal contention not raised before the Income-tax Officer, the Appellate Assistant Commissioner or the Tribunal cannot be entertained because it does not arise from the Tribunal's order. The court therefore rejected the assessee's attempt to argue, for the first time in reference, that the profit came from an unsuccessful attempt to start a new business. On the taxability issue, surplus from sale of dollars and sterling was treated as business income where the Tribunal found the foreign exchange transactions were incidental to the assessee's normal trading operations and supported by the record. The receipt was not regarded as a casual and non-recurring receipt and was not exempt under section 4(3)(vii). en-us Wed, 09 Dec 1959 00:00:00 +0530 Sat, 01 Aug 2020 13:53:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289474 In a section 66 reference, a new factual or legal contention not raised before the Income-tax Officer, the Appellate Assistant Commissioner or the Tribunal cannot be entertained because it does not arise from the Tribunal's order. The court therefore rejected the assessee's attempt to argue, for the first time in reference, that the profit came from an unsuccessful attempt to start a new business. On the taxability issue, surplus from sale of dollars and sterling was treated as business income where the Tribunal found the foreign exchange transactions were incidental to the assessee's normal trading operations and supported by the record. The receipt was not regarded as a casual and non-recurring receipt and was not exempt under section 4(3)(vii). Case-Laws Income Tax Wed, 09 Dec 1959 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289474