COMMISSIONER OF INCOME-TAX, MADRAS vs MAHALAKSHMI TEXTILE MILLS

The Supreme Court upheld the decision of the Appellate Tribunal regarding the admissibility of expenditure incurred for the Casablanca conversion system under Section 10(2)(v) of the Indian Income-tax Act, 1922. The Court clarified that the Tribunal has the authority to consider new contentions not raised before departmental authorities, as per Section 33(4) of the Act. The appeal by the Commissioner was dismissed, affirming that the right to relief for the assessee is not limited to the pleas initially raised.