COMMISSIONER OF INCOME TAX Vs. A VAIRAPRAKASAM

JUDGEMENT

(1.) THE substance of the question referred to us at the instance of the Revenue revolves round the meaning of the word "necessary" found in Explanation 1 to Section 64 of the Income-tax Act, 1961--whether it is to be construed liberally as contended by the Revenue or narrowly.

(2.) EXPLANATION 1 to Section 64 of the Act reads as under :

(3.) THE various shades of the meaning of the word "necessary" would indicate that a thing can be regarded as necessary only when there is an clement in the situation which compels a particular thing to be regarded as being essential or unavoidable.