COMMISSIONER OF INCOME TAX Vs. K J RAMASWAMY

JUDGEMENT

(1.) THE assessment years are 1981-82 and 1982-83.

(2.) THIS court in the case of CIT v. Sitalakshmi (Minor) [1996] 217 ITR 595, in circumstances were similar to those in this case, held in favour of the assessee and against the Revenue. That decision however would not apply to the facts of the case before us, as Explanation 2A to Section 64 was incorporated in the statute with effect from April 1, 1980, and remained a part of the statute till its repeal with effect from April 1, 1993. The assessment years with which we are concerned are 1981-82 and 1982-83. The decision relied upon by learned counsel is one which was rendered in relation to an assessment year prior to 1980.