1986 (1) TMI 152

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ed interest on compensation and for the relevant years to which the said interest pertained offered the same for taxation. The assessment year involved in 1981-82 and whatever interest was assignable for this year was offered for taxation by the assessee and subjected to tax. 3. The CIT in the light of certain case laws came to the conclusion that entire interest was to be included in the hands....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Soni (1981) 24 CTR (AP) 104 : (1982) 136 ITR 333 (AP), etc. against which the learned counsel for the assessee also came forward with a battery of decisions in support of assessee's contention viz. Joya Narayan Panigrahi vs. CIT (1974) 93 ITR 102 (Ori), CIT vs. Sampangirmaiah, V. (1968) 69 ITR 159 (Mys), CIT vs. Shamlal Narula (Dr.) (1972) 84 ITR 625 (P&H), Om Prakash vs. CIT (1984) 42 CTR (Del) 1....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....is of two view theory and our earlier decision on the merit alone we vacate the order of the CIT. Though we may also observe before we part as pointed out by the ld. counsel for the assessee that the payment was not received during the year under consideration because the assessment year involved is 1981-82 for which the relevant previous year ended on 31st March, 1981 whereas neither the date of ....