WELLPOINT SYSTEMS (P.) LTD Vs. INSPECTING ASSISTANT COMMISSIONER.

JUDGEMENT

(1.) THE assessed is aggrieved of the order dated 14 -12 -1988 of the learned Commissioner of Income Tax (Appeals) -XVI, New Delhi for the assessment year 1987 -88.

(2.) The assessed is a private limited company which manufactures pump sets as well as potato chips. The interesting point which arises in this appeal relates to the claim ability of deduction under Sec. 32AB which was inserted by the Finance Act, 1986 with effect from 1 -4 -1987. That provision is to the effect that where an assessed whose income includes income chargeable to tax under the head Profits and gains of business or profession has, subject to the other provisions of that section, out of such income, -

(3.) Before the learned Commissioner of Income Tax (appeals) submissions made on behalf of the assessed for justifying the claim of deduction under sec. 32AB were the following :