1996 (5) TMI 81

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... section 256(1) of the Income-tax Act, 1961, the following question has been referred for the opinion of this court : "Whether the Tribunal did not err in law as well as in facts in upholding the order of the Commissioner of Income-tax (Appeals) who directed the Assessing Officer to allow deduction under section 80HH in respect of the whole business even though there was no profit from the conc....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....igh Court in CIT v. N. C. Budharaja and Co. [1980] 121 ITR 212. At the request of the Revenue, the question referred to above has been referred for opinion of this court. We have heard Dr. A. K. Saraf, special counsel for the Revenue, and Mr. R. Goenka, counsel appearing on behalf of the respondent/assessee. Dr. Saraf submits that under section 80HH of the Income-tax Act, the assessee is ent....