COMMISSIONER OF INCOME TAX Vs. DENNIS H D

JUDGEMENT

(1.) THE 11 assessees concerned in the present reference were, at the material time, employees of the Caltex (India) Ltd. The facts in regard to 10 of the assessees are identical except the figures involved therein. Except in the case of Shri Ziegler in Ref. Appln. No. 48 of 1970 71, there is a dispute in regard to the validity of the assessment proceedings reopened under S. 147 (b) of the IT Act, 1961 (hereinafter referred to as "the Act"). Hence, both the questions which have been referred by the Tribunal under s.256(1) of the Act will have to be answered except in the case of the said Shri Ziegler.

(2.) THE assessment year involved in all 11 cases is 1963 64, the corresponding accounting period being the financial year 1st April, 1962, to 31st March, 1963.

(3.) THE relevant particulars as regard the salary income and tax benefits relating to Shri Dennis for the accounting year 1st April, 1962, to 31st March, 1963, are as under :