(1.) This appeal is filed by the Revenue raising the following questions as substantial questions of law arising from the order of the Income Tax Appellate Tribunal.
(2.) We may first consider the relevant sections. Section 10(4)(ii) is quoted below:
(3.) Before going into the rival contentions, we may also refer to the budget speech of the Finance Minister and Memorandum explaining the Finance Bill for 1983-84 while the above section was introduced (See: (1983) 140 ITR 27) as well as object of incorporating Section 115. Budget speech reads as follows: