1987 (4) TMI 38

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....ny received from the Andhra Pradesh Paper Mills Ltd., as part of the consideration for the technical know-how supplied by the former to the latter) as profit attributable to its priority industry for the purpose of the deduction under section 80-I of the Income-tax Act, 1961, for the assessment year 1969-70 ? 2. Whether, on the facts and in the circumstances of the case and in law, the Tribunal was justified in holding that the profit of Rs. 1,78,606 on the sale of the assets and miscellaneous receipts of Rs. 2,65,548 should be included in the profits attributable to the priority industry for the purpose of the deduction under section 80-1 of the Income-tax Act, 1961 ?" For the assessment year 1970-71, only one question is raised, whi....

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....re of such products; and "Whereas, West Coast is presently engaged in the production of pulp and paper from bamboo since last 5 years with a quality production of 30,000 tons of paper per annum; and Whereas, West Coast is willing to furnish such collaboration to Andhra Paper subject to the provisions of this Agreement; ..." The assessee claimed deduction under section 80-1 of the fees that it received from the said company on the ground that they constituted a part of its profits and gains attributable to its said priority industry. The Income-tax Officer rejected the claim on the ground that such deductions would be admissible only in regard to the profits that directly emerged from the manufacture and sale of paper. In appeal, th....