COMMISSIONER OF INCOME TAX vs SIRPUR PAPER MILLS

The Supreme Court ruled that under Section 36(1)(iv) of the Income Tax Act, the entire initial contribution made to an approved superannuation fund is allowable as a deduction. The Court upheld the decision of the Commissioner of Income-Tax (Appeals) and the Income Tax Appellate Tribunal, which had allowed the full deduction despite the Income Tax Officer's limitation to 80%. The Court emphasized that the Revenue's appeal was dismissed on technical grounds, affirming the lower authorities' decisions.