COMMISSIONER OF INCOME TAX Vs. TUNGABHADRA INDUSTRIES LTD

JUDGEMENT

(1.) There are two consolidated references for the assessment year 1984-85 made by the Tribunal under Section 256(1) of the Income-tax Act, 1961, one at the instance of the assessee and the other at the instance of the Revenue. At the instance of the Revenue, the following question of law has been referred to this court :

(2.) The following questions of law have been referred at the instance of the assessee :

(3.) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the expenditure incurred on repairs and insurance of cars should be considered for the purpose of computing disallowance under Section 37(3A) of the Income-tax Act, 1961, and that such an expenditure is not allowable under Section 31 of the said Act ?"