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1983 (5) TMI 39

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....e appeal relates to the assessment year 1979-80. During the previous year relevant to this assessment year, the assessee participated in the contest of Bombay Dyeing & Manufacturing Co. Ltd., Bombay for caption writing by completing a sentence praising Bombay Dyeing fabrics in a few words. The assessee's entry was adjudged for a prize and the assessee got a prize of Rs. 30,000 for this caption wri....

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.... 124 ITR 85, dealt with winnings from races where the winnings were without any effort, exertion or skill and, therefore, this ruling of the Hon'ble High Court of Madras will not be applicable in the assessee's case. The assessee, therefore, submitted that the prize money of Rs. 30,000 received by the assessee could not be called a windfall or, alternatively, it cannot be equated with lottery winn....

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.... We have carefully considered the rival submissions. Their Lordships of the Hon'ble Supreme Court in the case of Navinchandra Mafatlal v. CIT [1954] 26 ITR 758 quoted with approval the observations of their Lordships of the Privy Council in the case of Raja Bahadur Kamakshya Narain Singh of Ramgarh v. CIT [1943] 11 ITR 513 that 'income' is a word difficult and perhaps impossible to define in any p....

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...., therefore, that remains is whether this income is entitled to exemption under section 10(17A). Section 10(17A) as it then stood for the assessment year 1979-80, reads as follows : " (17A) any payment made, whether in cash or in kind, in pursuance of awards for literary, scientific and artistic work or attainment, or for proficiency in sports and games, instituted by the Central Government or by....