1989 (8) TMI 3

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....llowing question of law to this court under section 256(1) of the, Income-tax Act, 1961 ("the Act") : "Whether, on the facts and in the circumstances of the case and on a correct interpretation of the agreement dated July 14, 1976, between the assessee and the Ali Akbar College of Music, the Tribunal was justified in holding that the remuneration received by the assessee was assessable not as s....

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....he contention of the as and held that the assessee was an employee of the Ali Akbar College of Music. Accordingly, the income should come under the he, On appeal, the Appellate Assistant Commissioner held that was liable to be taxed under section 5(1)(c) of the Act, and the of section 6(1)(ii) (sic) of the Act could not be invoked for the income as income under the head "Salaries". The Appellate A....

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....so pointed out one more aspect of the case which had escaped the attention of the lower authorities. The Tribunal pointed out that section 80R of the Act was enacted with effect from April 1, 1968, and was applicable to the assessment year under consideration. Section 80R allows a deduction of half of the total remuneration received by an individual who is a citizen of India where the remuneration....