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1987 (8) TMI 163

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.... the assessment year 1980-81 there is one additional point with reference to the computation of the extra shift allowance. The contention of the Revenue is that the extra shift allowance should be computed with reference to each individual machine and not with reference to the working of the concern as such even though that is the procedure laid down by the circular of the CBDT No. F. 10/83/8/ITA-....

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.... would make the circular redundant. But the other aspect is with reference to the concession granted by the CBDT against the rigour of the statute either to grant relief or to simplify the procedure. This kind of a circular would be binding on the revenue. This dichotomy and the effects thereof have been adumbrated by the Supreme Court in the case of K. P. Varghese v. ITO [1981] 131 ITR 597. In vi....