This appeal by assessee relates to assessment year 1980-81. assessee is registered firm consisting of two partners. business run was that of exclusive retail shop of Bombay Dyeing & Manufacturing Ltd. Supplies of clothe were obtained by assessee through wholesale distributors of Bombay Dyeing and Mfg. Co. Ltd. (the principals), i.e., Shivram Associates (the distributors). In year of account, assessee received amount of Rs. 50,000, which was equivalent to cost of Ambassador car from principals. principals had celebrated centenary year and in that connection had brought out Suiting Incentive Scheme under which assessee received aforesaid amount. Extracts from relevant pamphlet containing details of incentive scheme are as under: "Bombay Dyeing has recently introduced several new and exciting varieties i n its range of Polyester and Polyster-blended suitings ... we can thus offer discriminating customers truly extensive selection of exclusive suitings like ... ... to enable you to stock and sell more of these fabulous suitings, we offer Bombay Dyeing Retailers host of incentives like: higher margin For delivery at destination Publicity support . . . opportunity to pick and choose varieties and designs your customers ask for most. Now, for you, new exciting gift scheme We want you to put in little extra effort, to try and sell Bombay Dyeing Suitings. And now, to make it worth your while we offer you gifts galore. Naturally, more Bombay Dyeing Suitings you stock and sell, more attractive gifts you will get. Bombay Dyeing's special centenary gift scheme From 1st December, 1978 to 30th November, 1979, on your total purchase of Bombay Dyeing Suitings worth Rs. 75,000 or more from any of our approved wholesale dealers you will be entitled to exciting gifts detailed below:" To match quantity of purchases, various gifts were offered. minimum purchase for eligibility for gift was Rs. 75,000 and maximum purchase was for Rs. 8 lakhs or more. assessee-firm became eligible because of purchase of Polyester suitings worth Rs. 8 lakhs. gifts permissible under this category were: "35 days' package tour of USA and Europe (for 2) or Ambassador car o r cash register, ply-Fedders-Lloyd 3 ton air-conditioner or various other items like refrigerator, typewriter, etc., etc." assessee received in lieu of Ambassador car, amount of Rs. 50,000. In this regard it would also be relevant to set out assessee's letter dated 10-12-1979 to distributors: "We are pleased to inform you that we have purchased Bombay Dyeing Suitings for Rs. 8,00,540.63 during period 1-12-1978 to 5-12-1979. statement showing invoice-wise, value of suitings purchased by us is enclosed for your records. We take this opportunity to thank you for your co-operation in arranging timely supplies of suitings, which enabled us to achieve target of Rs. 8 lakhs. We once again thank you for all efforts you have taken in making gift scheme for suitings, grand success. Thanking you" reply dated 1-3-1980 from distributors to assessee is as below: "Congratulations: Your unstinted efforts coupled with personal qualities of high business skill have borne fruits. Our principal Bombay Dyeing & Mfg. Co. Ltd., Bombay, expressed great appreciation for your indefatigable endeavour in achieving targets of purchases as fixed by them and in appreciation of your efforts to boost up suiting sales, you are offered on Ambassador car of your choice under Mill's Gift Scheme. This gift, is no doubt, purely in recognition of your personal qualities and fine team effort." 2. In filing return originally, amount of Rs. 50,000 was not shown; but revised return was filed claiming amount as exempt from taxation. ITO observed that receipt was foreseen and anticipated and, therefore, could not be considered as casual or non-recurring to be eligible for exclusion under section 10(3) of Income-tax Act, 1961 ('the Act"). ITO, therefore, included amount of Rs. 50,000 in making assessment. 3. assessee appealed and reiterated before AAC stand that amount was not taxable. assessee relied on decision of Tribunal (Madras Bench 'B') in case of Rasi Exports (P.) Ltd. v. ITO [IT Appeal No. 360 (Mad.) of 1980 dated 30-3-1981] as also judicial pronouncements in CIT v. Ramalakshmi Reddy [1981] 131 ITR 415 (Mad.) and CIT v. Groz-Beckert Saboo Ltd. [1979] 116 ITR 125 (SC). 4. AAC observed that facts in case of Rasi Exports (P.) Ltd.'s case (supra) were materially different and value of collar turning machine was held to be exempt because receipt of such machine was never in contemplation at any stage prior to receipt of gift. Eventually, AAC upheld inclusion of amount of Rs. 50,000. 5. Before us, learned counsel for assessee again relied on order of Tribunal in case of Rasi Exports (P.) Ltd. (supra) and other judicial pronouncements on which reliance was placed before AAC. It was reiterated that receipt was capital receipt and in nature of bounty or gift and could not be subjected to tax. 6. learned departmental representative, on other hand, submitted that there was direct nexus between receipt of amount and business carried on by assessee and amount was clearly taxable under provisions of section 28 of Act, and in particular, provisions of section 28(iv). 7. We have considered rival, submissions. From facts set out, it is clear that in present case, to mark centenary of principals, they had come out with scheme offering incentives or prizes. Such incentives or prizes were based on amount of purchases that particular retailer made. larger purchases made, larger incentive offered. Therefore, before, embarking on purchases, assessee was aware that if certain specific targets were exceeded that would become eligible for gifts which were offered under gift. From facts ascertained, crucial point which emerges is that purchases made were for with expectation of obtaining gift. gift obtained by assessee was as much reward for good business done as incentives obtained in form of import licences, etc., under export promotion scheme and in such cases Courts have uniformly held that value was taxable. decision in this regard are Kesoram Industries & Cotton Mills Ltd. v. CIT [1978] 115 ITR 143 (Cal.) and CIT v. Swadeshi Cotton Mills Co. Ltd. [1980] 121 ITR 747 (All.), etc. ratio of order of Tribunal in case of Rasi Exports (P.) Ltd. (supra) has no application here because there, when goods were exported, assessee had no knowledge that foreign customer would send them gifts of collar turning machine. Tribunals has clearly pointed out in para 4 of its order that receipt of such gift was never in contemplation at any stage and further in para 5 they have stated that there was no material to show that machine was received in pursuance of agreement either tacit or written. decision of Supreme Court is case of Groz-Beckert Saboo Ltd. (supra) has also no application to facts in present case. This is not case where gift has been received as capital asset unlike in that case where gifts were received along with certain machinery supplied for setting up factory in India. For all aforesaid reasons, we hold that amount of Rs. 50,000 has rightly been brought to tax. 8. In result, appeal of assessee is dismissed. *** BOEING v. INCOME TAX OFFICER