1991 (8) TMI 18

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.... 1961, for the assessment year 1980-81, the following two questions of law have been referred to this court : " 1. Whether, on the facts and in the circumstances of the case, the Tribunal failed to take proper note of Clause VI of the deed of assignment dated September 3, 1966, and whether, on the facts and the circumstances of the case, the Tribunal was justified in holding that, M/s. Park Hot....

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....see. The second question pertains to the assessment of income from electricity charges under the head " Other sources ". The ground of appeal raised before the Tribunal was as under : " That the Commissioner of Income-tax (Appeals) erred in law as well as on facts in entertaining electricity charges as income from 'other sources' and changing it to as income from 'business' since that ground wa....

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.... Inspecting Assistant Commissioner. The Inspecting Assistant Commissioner, in his direction under section 144B(4) for the assessment year 1980-81, has considered the assessee's contention that electricity charges realised from the parties should have been assessed as income from business and not as income from other sources. So, it is not correct to say that such ground was not raised before the I....