1984 (2) TMI 178

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.... ends in the subsequent year i.e. on 30th Jan., 1981 relevant the asst. yr. 1982-83. According to the assessee the foreign income received should be assessed for the year 1982-83. In this connection he also placed reliance on the decision of Andhra Pradesh High Court in Addl. CIT A.P. vs. K. Ramachandra Rao (1981) 20 CTR (AP) 60 : (1981) 127 ITR 414 (AP). But however, the ITO was not agreeable to the submissions made by the assessee. According to him the decision cited by the assessee stands on a different footing. According to the ITO, the source of income is the same i.e. salary for both the Indian and foreign incomes while in the case cited by the assessee there are two different sources of income i.e. income from profession and income f....

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....tor of Vijaya Commercial Bank. Until the asst. yr. 1968-69, he was being assessed under two heads viz. profession and salary and the salary income of the assessee received from Indian Law Reports and Vijaya Commercial Bank was being assessed under the latter head, the previous year chosen ending on 31st March of every year. He was appointed as a judge of the Andhra Pradesh High Court on 21st Aug., 1968. For the asst. yr. 1969-70, the assessee claimed that he maintained separate accounts in respect of salary income as a judge and made up accounts for the previous year ending on 31st July, 1969 and, therefore, it should be assessed in the asst. yr. 1970-71 and not 1969-70. On these facts, the Andhra Pradesh High Court held that the election o....