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Commissioner Of Income-Tax, West ... vs Isthmian Steamship Lines on 12 November, 1951

The unit for applying the Act is the assessment year. Until recently, the previous years differed from assessee to assessee. It could be the preceding financial year or any other period of 12 months ending on any date in the previous financial year. That this is so is made clear by several decisions including Reliance and Industries Ltd. v. CIT [1979] 120 ITR 921 (SC), CIT v. Isthmian Steamship Lines [1951] 20 ITR 572 (SC) and other decisions collated at page 110 of Kanga and Palkhivala's The Law and Practice of Income Tax, 8th edition, Volume 1. We do not think it necessary to reiterate all the decisions on this question inasmuch as we have held that whether it is the unamended Section 12 or the amended Section 12, the question must be answered in favour of the assessee.
Supreme Court of India Cites 4 - Cited by 74 - Full Document

Reliance Jute & Industries Ltd vs C.I.T., West Bengal, Calcutta on 10 October, 1979

The unit for applying the Act is the assessment year. Until recently, the previous years differed from assessee to assessee. It could be the preceding financial year or any other period of 12 months ending on any date in the previous financial year. That this is so is made clear by several decisions including Reliance and Industries Ltd. v. CIT [1979] 120 ITR 921 (SC), CIT v. Isthmian Steamship Lines [1951] 20 ITR 572 (SC) and other decisions collated at page 110 of Kanga and Palkhivala's The Law and Practice of Income Tax, 8th edition, Volume 1. We do not think it necessary to reiterate all the decisions on this question inasmuch as we have held that whether it is the unamended Section 12 or the amended Section 12, the question must be answered in favour of the assessee.
Supreme Court of India Cites 8 - Cited by 253 - R S Pathak - Full Document
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