(1.) The petitioner is aggrieved by the order passed by the Assessing Authority that the petitioner was not entitled to deduction either in terms of Section 80 RRA of Income Tax Act or Section 80-0 of the Income Tax Act.
(2.) It is the case of the petitioner that the petitioner after his retirement from Steel Authority of India Limited as Executive Director beacame Advisor to M/s.Davy Mckee, U.K. vide their letter 4/12/1991 at a monthly remueration of 600.00 pounds sterling. The petitioenr sought permission of the Reserve Bank of India which is at pages 22 to 25 of the paper book. The petitioner filed the tax returns for the assessment year 1993-1994 where the asessment order at page 28 of the paper book was passed by the respondent. Aggrieved by Section 80RRA of Income Tax Act before the Appropriate Authority.
(3.) Joint Secretary to the Government of India, Ministry of Finance, (Department of Revenue), Central Board of Direct Taxes is the appropriate authority. Joint Secretary vide his letter dated 4/9/1996 took the view that the petitioner was not qualified for grant of approval under Section 80 RRA of Income Tax Act.