COMMISSIONER OF INCOME TAX Vs. VYSYA BANK LIMITED

JUDGEMENT

(1.) IN this reference case, the Tribunal somewhat strangely had referred the following question for answer by us under section 256(1) of the INcome-tax Act, 1961 (for short "the Act") :

(2.) IN this context, we should not fail to notice that reliance placed by learned counsel for the assessee before us on the decision of the Supreme Court in Cocanada Radhaswami Bank Ltd.,'s case is inapposite. IN that case. What was explained by the Supreme Court was the totality of the taxable income under various heads. The Supreme Court did not examine the scope for claiming allowance under relevant provisions of the Act for the purpose of relief. Therefore, that decision cannot assist the assessee in furthering the contention that all sources of income must have the benefit of section 37(2A).