RAUNAQ INTERNATIONAL Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THIS is a reference under S. 256(1) of the INCOME TAX ACT, 1961, arising out of the asst. year 1974 -75 and made at the instance of the assessee seeking the opinion of the High Court on the following question of law :

(2.) THE plea raised on behalf of the assessee was that the transfer of import entitlements amounted to a transfer of source of income and, therefore, should not be treated as revenue receipt. This plea did not find favour with the Tribunal and the premium earned by the assessee has been held liable to tax.

(3.) OR the foregoing reasons, the reference is held to have been rendered academic merely and hence is returned unanswered.