1989 (2) TMI 406

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....KAYLE LIMITED. In the reference under section 256(1) of the Income-tax Act, 1961 ('the Act'), the question referred for our opinion is as under: "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal is right in law in holding that the assessee is entitled for deduction under section 35(1)(iv) of the amount of Rs. 2,83,310 spent on the purchase of buse....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... the purposes of facilitating research. The claim was made on the ground that the buses were used to transport the research personnel and was not related to the business of the assessee other than scientific research. The ITO was of the view that this was a conveyance which the assessee was required to provide in respect of its employees and it was the normal transportation expenses, and the mere ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....the conclusion, the Tribunal relied on the definition of the words 'scientific research' given in section 43(4)(i) of the Act as also the Explanation given under section 43(4)(ii), which read as under: "4. 'Scientific research' means any activities for the extension of knowledge in the fields of natural or applied science including agriculture, animal husbandry or fisherie....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....scientific research or facilities for the prosecution bf scientific research, and the buses meant for providing conveyance to the scientific personnel to travel from their respective residences to the factory, cannot be regarded as a facility for the prosecution of scientific research. Sri Sarangan, the learned counsel for the assessee, however, submitted that the language used in the explanation ....