COMMISSIONER OF INCOME TAX Vs. RAJASEKARAN BALASUBRAMANIAM

JUDGEMENT

(1.) Aggrieved by the order of the Tribunal in dismissing the appeal filed by it, the Revenue is before this Court by filing this appeal raising the following questions of law :-

(2.) The facts, in a nutshell, are as hereunder :-

(3.) Aggrieved by the said order of the assessing officer, the assessee filed appeal before the CIT (Appeals). The CIT (Appeals) held that the hypothetical tax has been brought in to bring in tax equalization between domestic employment and overseas employment and, hence, the hypothetical tax cannot be a subject of addition and allowed the appeal. Aggrieved by the order of the CIT (Appeals), the Revenue preferred appeal before the Tribunal.