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The Commissioner Of Income Tax, ... vs Indian Institute Of Public Opinion Co. ... on 10 September, 1981

The assessee has, naturally, placed considerable reliance on the approval granted by the Board under section 80-O and, in particular, on the 105 Clarification issued by the Board on 31.7.85 after the assessee's representation, by deleting the reference to section 80-HHB. The Department has sought to retaliate by taking up the stand that the contracts in the present case do not at all fall under section 80-O and that the Board erred altogether in granting such approval. The Tribunal accepted a suggestion put forward on behalf of the Department that the clarification was the result of some confusion and purported to obtain a further clarification from the Board in a manner that has attracted vehement complaint and criticism from the assessee. We do not think it is necessary for us to enter into this realm of debate for, apart from the doubtful sustainability of a collateral attack by the Department on an approval granted by the highest administrative authority under the Act, we have endeavoured to point out that the Board was fully justified in considering the receipts of the assessee as falling under section 80-O and in granting approval to the contract. We shall also proceed on the footing that the assessee is also right in saying that the Board had, after considering its representations, accepted the position that the approval under section 80-O would ensure also for the assessment year 1983-84 onwards. In fact, we think that, irrespective of the Board's clarification of 1985, the correct position is that, once a contract stands approved under section 80-O in relation to the first assessment year in relation to which the approval is sought, the approval ensures for the entire duration of the contract. This is the principle enunciated in C.I.T. v. Institute of Public Opinion, (1982) 134 I.T.R. 23 (Del.) the correctness of which cannot be doubted and is, indeed, accepted by both counsel before us. Section 80-O does not envisage an application for approval of the contract every assessment year or the limitation of the approval granted by the Board to any particular assessment year. The Board is approving of a contract having regard to the nature of the receipts flowing therefrom and once this approval is granted, the assessee is entitled to seek a deduction under section 80-O in respect of all the receipts under the contract the consideration for which is traceable to the three ingredients discussed earlier irrespective of the assessment year in which the receipts fall for assessment. The Board's approval of the contract - in 1983 as well as in 1985 - has no doubt this effect. But this is not the same thing as saying that relief under section 80-O would be available despite section 80-HHB. It seems to us that the Board's clarification of 31.7.1985 (which merely withdraws the reference to section 80-HHB and extends the approval beyond 1982-83) cannot be read as involving a further decision that the assessee should be granted relief under section 80-O contrary to the terms of section 80-HHB. Section 80-O only empowers the Board to approve of a contract on being satisfied that it gives rise to receipts qualifying for deduction under section 80-O and nothing more.
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