1985 (5) TMI 19

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....elevant accounting year is the year ending September 30, 1966. The assessee is company which is engaged in the business of hiring out navigation receivers and equipment to its various customers in India. Such navigation receivers and equipment are in turn taken on hire by the assessee from Dacca Navigation Concessions Ltd., London (hereinafter referred to as the "London company "), vide an agreement dated December 19, 1961. The dispute before the Tribunal was in regard to an additional liability arising from the devaluation of Indian currency on June 6, 1966. The Income-tax Officer disallowed the said additional liability due to devaluation of Indian currency on June 6, 1966, amounting to Rs. 57,103 because, in his opinion, the said sum ....

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....ty were, therefore, part and parcel of the same transaction, namely, the receipt of navigation receivers and equipment on hire from the London company. The Tribunal was of the opinion that the liability of Rs. 57,103 was not a separate and distinct liability apart from the original transaction of payment of hire charges by the assessee. It was also of the view that there was no distinction between hire charges credited to the account of the London company in the earlier years and the hire charges now credited in the year 1966. The Tribunal, therefore, held that as the original credit was allowed as a deduction to the assessee, the credit now given to the account of the London company should also be allowed as a deduction. The Tribunal furth....