1983 (5) TMI 39

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....for a prize and the assessee got a prize of Rs. 30,000 for this caption writing. It was claimed before the ITO that this amount was a windfall or, alternatively, it was exempt under section 10(17A) of the Income-tax Act, 1961 ('the Act'). The ITO, however, did not accept this claim and included the prize of Rs. 30,000 in the assessee's total income. When the matter went up in appeal, the AAC held that this amount of Rs. 30,000 was income within the meaning of section 2(24)(ix) of the Act and that it was not entitled to exemption under section 10(17A). He, therefore, upheld this addition made by the ITO and dismissed the assessee's appeal. The assessee has, therefore, come up in the present appeal before us. 3. The assessee's learned coun....

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....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 precise general formula and is a word of the broadest connotation. Even the definition of the word 'income' appearing in section 2(24) is merely inclusive and not exhaustive and, therefore, a very wide meaning should be given to this expression in order to include almost every kind of receipt or gain and also the notional incomes mentioned in clause (24) of section 2. Viewed in this context, it is not under dispute that the assessee put in his skill, exertion and effort for participating in the Bombay Dyeing cont....