UNITED BREWERIES LIMITED Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THE Income-tax Appellate Tribunal, Bangalore Bench, (hereinafter referred to as "the Tribunal"), at the instance of the assessee has referred the following question of law for the opinion of this court :

(2.) IN order to appreciate the question referred to us, it is necessary to notice, in the first instance, the facts as found by the Tribunal.

(3.) MR. K. Srinivasan, learned senior standing counsel for the Revenue, submitted that legal expenses are not incurred wholly and exclusively for the purpose of safeguarding the investments or earning dividends or for the purpose of the business of the assessee and, therefore, not allowable.