2007 (4) TMI 61

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... Appellate Tribunal, Delhi Bench A in ITA No.2590/Del/2002 relevant for the assessment year 1987-88 and ITA No.2591/Del/2002 relevant for the assessment year 1998-99. 2. The sole question that has arisen in this appeal is whether the Assessee who is entitled to exemption under Section 10(22) of the Income Tax Act, 1961 can claim the benefit thereof for the purpose of income deemed to be chargea....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....9) of the Act which uses the expression 'derived from' which expression is missing in Section 10(22) of the Act. The Supreme Court held that the expression 'derived from' is intended to give a restrictive meaning to the word 'income' as used in Section 10(29) of the Act and, therefore, proceeding on that basis, the Supreme Court decided against the assessee. 6. We find that the words 'derived f....