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Citation: 1972 PTD 445
Court: Gujarat High Court
Year: 1971
Decision Date: 1971-12-31
Parties: COMMISSIONER OF INCOME-TAX, GUJARAT II vs ALEMBIC GLASS INDUSTRIES JUDGMENT
Case cited as 1972 PTD 445
Court Name: Gujarat High Court Judge(s): P. N. Bhagabati, Divan Title:COMMISSIONER OF INCOME-TAX, GUJARAT II vs ALEMBIC GLASS INDUSTRIES JUDGMENT Reported As: 1972 PTD 445 Result: appeals confirm Judgment JUDGMENT DIVAN, J.-In this reference two assessm ent years are involved and this joint reference has been made under section 66(1) of the Income-tax Act, 1922, and section 256(1) of the Income-tax Act, 1961. The assessm ent years are 1961-62 and 1962-63, the corresponding previous years being the calendar years 1960 and 1961. The assessee Is a company manufacturing glassware ; and it deputed three of its technicians to the United States of America to enable them to obtain practical training In the manufacture of heat-resisting glassware. The training was imparted by Thatcher Glass Manufacturing Co. Incorporated in the U. S. A. In connection with this practical training, the assessee-company paid a sum of Rs. 71,625 (15,000 dollars) by way of fee to Thatcher Glass Manufacturing Co. And a further sum of Rs. 56,302 was spent by the assessee-company for the assessm ent year 1961-62 for travelling, lodging and other expenses of the employees. A further sum of Rs. 3,489 was spent in the same connection by the assessee-company so far as the assessment year 1962-63 was concerned ; and the company claimed the amounts of Rs. 71,625 and Rs. 56,302 as items of revenue expenditure for the assessment year 1961-62, and the sum of Rs. 3,489 as revenue expenditure for the assessm ent year…
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