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1978 (8) TMI 64

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....-The assessee in these two cases is M/s. Kirloskar Asea Ltd., Bangalore, and the assessment years are 1970-71 and 1971-72. Under a collaboration agreement entered into with a Swedish concern styled as " ALINANNA SUENSKA ELECTRISKA AKTIEBOLAGIE " (ASEA), the said concern subscribed $ 2,52,000.26 towards the assessee's share capital and that amount was deposited in the assessee's name in a bank in S....

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.... the ITO and directed him to allow the reliefs prayed for at the post-devaluation rates. In the second appeal filed by the department, the Income-tax Appellate Tribunal, Bangalore Bench, reversed the decision of the AAC and restored the decision of the ITO on the above question. At the instance of the assessee, the following question has been referred to us in each of the above cases under s. 256(....