Supreme Court · 1977 INSC 110 · Decided 11 April 1977
M/S. Carborandum CO. v. C.I.T., Madras
- Court
- Supreme Court of India
- Citation
- 1977 INSC 110 · [1977] 3 S.C.R. 475
- Case number
- CIVIL APPEAL No. 89/1975
- Decided
- 11 April 1977
- Bench
- P.N. BHAGWATI, N.L. UNTWALIA, S. MURTAZA FAZAL ALI (3-judge bench)
- Outcome
- Appeal(s) allowed
- Case type
- Civil
- Acts & sections cited
- Income Tax Act
Headnote
/11con1e-tax Act, 1922-S. 4(1)(e)-Distinction between concept of actual accrual and notion on deenied accrual-Reference under lncome-tnx Act, 1922- New facts neither raised nor considered by the Tribunal cannot be entertailled by the Hij[h Court at reference s/af?e. · Inco111e-tax Act, company \vithin the Il1eaning of s. 2(5.·\) of Jncome Tax Act, entered into an agreement with 1\1/s. Carborandum UniversaJ Ltd., _..,,,- having its registered office at 1\Iadras on June 22, 1955 and rendered certain technical and knowhow services. In view of the said services it \vas to
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