deviation, if
any, from the method of valuation prescribed under Section 145A and
the effect thereof on the profit and loss, the petitioner failed ... there is no deviation from the method of valuation
prescribed under Section 145A of the Act. According to Mr.Parikh,
such disclosure with respect
further contended that the Rules having been framed not
only under section 145A of the Act but also in compliance with the
requirement provided ... beyond the scope of legislative delegation provided under section
145A or section 168 .
In
order to appreciate the aforesaid contentions, it will be profitable
said
deceased bequeathed his one-third share in the Premises No.145A, Cotton Street,
Calcutta-7 in favour of the executor depriving the other heirs ... third share of the income from the property situated
at 145A, Cotton street, Calcutta.
(e) The executor should go on making payment
80HHC of the Act by
totally overlooking the provisions contained in Section
145A of the Act.
(B) Whether the Tribunal below committed substantial error
Income Tax Act, 1961 ["the Act"]
despite insertion of Section 145A by relying upon the decision of
the Supreme Court in the case ... April 1, 1999, the date of coming into operation of Section
145A .
[B] Whether
the Tribunal below committed substantial error of law
in directing
Section 80HHC of
the Act, by overlooking the provision contained in Section 145A of
the Act.
[3] Whether the
Tribunal below committed substantial error
Income Tax Act in
contravention of the provisions of Section 145A which has
been amended with effect from April 1, 1999.
(BHASKAR BHATTACHARYA, ACTING