1965 (12) TMI 38

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....der section 66A(2) of the Indian Income-tax Act, 1922, hereinafter referred to as the Act, read with section 261 of the Indian Income-tax Act, 1961, are directed against the judgment of the Rajasthan High Court in a consolidated reference made to it by the Appellate Tribunal. These appeals relate to the assessment years 1945-46 and 1946-47. The question referred at the instance of the appellant wa....

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....nd 25% for the selling process." Mr. Viswanatha Sastri, the learned counsel for the appellant, contended that on the facts of this case the assessee was liable to tax not on accrual basis but on receipt basis. When asked how does the revenue suffer by the amounts involved in these assessment years being taxed on accrual basis rather than on receipt basis, the learned counsel frankly and properly....

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....s to the amount of profits which arose on the amounts received by the assessee's bankers. The appellate order of the Appellate Tribunal does not contain any discussion on the point as to the correct manner of apportioning profits between the manufacturing process and the selling process. Apparently, the High Court felt that as they had substituted the accrual basis for the receipt basis, they also....