This is departmental appeal against order of Appellate Assistant Commissioner, 'B' Range, Hyderabad, dated 20-3-1985 and it relates to assessment year 1980-81. 2. assessee is individual. He had participated in Amrutanjan Slogan Contest which announced Premier Padmini car or Rs. 40,000 as first prize for best entry. conditions of contest were that contestant had to fill entry form mentioning effect of Amritanjan on body when it is applied and also to coin slogan on Amritanjan. decision of company was final and binding. assessee won first prize in contest and opted for Premier Padmini car in preference to cash of Rs. 40,000. In his first return dated 19-8-1980 he declared income of Rs. 40,000 as winnings from lottery and claimed deduction under section 80T. However, vide revised return dated 25-11-1981 assessee claimed that income received from prize winning from Amritanjan company was totally exempt from tax as it was casual and non-recurring. Income-tax Officer did not agree with contention of assessee and taxed income at Rs. 39,000 under section 2(24)(ix) of Income-tax Act. 3. Before Appellate Assistant Commissioner in appeal it was urged that winning from slogan contest organized by company does not fall under section 2(24)(ix) of IT Act and it is not income at all to be returned. It was kly contended that winning of prize in said contest requires skill and expertise and it does not depend upon chance, luck, etc. assessee relied upon Madras High Court decision in CIT v. G.R. Karthikeyan [1980] 124 ITR 85. Appellate Assistant Commissioner after having read Madras High Court ruling and also having regard to wording in section 2(24)(ix) of Income-tax Act felt that income as defined under section 2(24)(ix) refers to chance winning only. He had recorded finding that in instant contest prize was won in competition where use of intelligence and skill was paramount and therefore it cannot be held that prize was either casual non- recurring receipt nor income as defined in section 2(24)(ix) of IT Act. He also relied upon Jodhani Nina Pitamber v. ITO [1982] 1 ITD 332 (Indore). In result, he allowed appeal and deleted Rs. 39,000 from income computed by Income-tax Officer. 4. As against impugned order passed by Appellate Assistant Commissioner department came up in second appeal. According to department Appellate Assistant Commissioner ought to have confirmed assessment of amount as casual and non-recurring income since income w s derived by mere chance or it was casual receipt and there was no certainty of assessee's slogan for being picked up for prize. Therefore winning of amount of Rs. 40,000 is akin to winning from competition in nature of lottery. Therefore, it should be taxed as income under section 2(24)(ix) of IT Act. Shri K.C. Devdas, kly relied upon Appellate Assistant Commissioner's order and two decisions relied upon by Appellate Assistant Commissioner in support of his connection. 5. Section 2(24)(ix) of Act was introduced from 1-4-1972 and it reads as follows: "any winnings from lotteries, cross-word puzzles, races, including horse races, card games and other games of any sort or from gambling, betting of any form or nature whatsoever." In G.R. Karthikeyans' case (supra) meaning of word 'winnings' used in section was found out from Universal Dictionary of English Language by Henry Ceicil Wyld, Rentledge and Kagan Paul Ltd., London, 1952 Edn. and there it was given as 'amount won, esp. money won in betting'. In Oxford English Dictionary (Compact Edn., Vol. II, p. 178, Col. 3, Item 4), word 'winnings' is given following meaning: "Things or sums gained, gains, profits, earnings (obs. or dial.) in modern use chiefly applied to money won by gambling or betting". Having had advantage of meaning to word 'winnings' their Lordships of Madras High Court held that definition shows that word is used in association with chance rather than skill. In singular form of winning meaning assigned to that expression is: "1. act of person or thing that wins. 2. Usually winnings-that which is own especially money." (See Random House Dictionary of English Language, College Edn., at page 151). In Webster's Third International Dictionary word 'winnings' is given this meaning: "Something one wins esp. money won by success in competition." Having observed separate meanings given to words in plural as well as singular forms, 'winnings' Madras High Court held that as far as plural form is concerned it is given specific meaning in Oxford Dictionary. Especially in current or modern usage, it is chiefly applied to 'money won by gambling or betting'. Though expression would in olden days comprehend all things or sums gained, gains, profits, earnings, still its modern usage is confined to money won by gambling or betting. 6. In case before Madras High Court assessee participated in All India Highway Motor Rally. According to rules governing rally emphasis was on endurance driving and was designed as reliability test for automobiles. race was to be run having due regard to traffic regulations at different places and prize was to be ascertained by adopting system of penalty points for violation of traffic rules and regulations. competitor with least penalty points was adjudged as successful among participants. assessee won first prize in rally and received Rs. 20,000 from Indian Oil Corporation and another sum Rs. 2,000 from All India Motor Rally. Income-tax Officer brought to tax Rs. 22,000 invoking provisions of section 2(24)(ix) of IT Act in view that amount represented winning from races. 7. Appellate Assistant Commissioner held that contest was not race and hence amount could not be taxed. Tribunal agreed with views. On reference High Court held that accordingly ordinary use of expression 'winnings' would not comprehend winning of prize in case of this kind. Tribunal was therefore right in its conclusion. 8. In this case also having regard to dictionary meanings for word 'winnings' already considered by Madras High Court we are unable to hold that prize was received by assessee only by chance or luck. We hold that in order to receive prize sort of skill is also essential to be exhibited and therefore prize received by assessee does not come under winnings or races or games. Coining slogans cannot be termed to be either race or game of chance. Therefore, in our opinion, ratio of Madras High Court decision fully applies to facts of case. Further in Jodhani Nina Pitamber's case (supra), Single Member of Indore Bench of Tribunal took view that in case of assessee who won first prize in All India Competition by answering all questions correctly was held not to be income under section 2(24)(ix) of IT Act. Having regard to these decisions which we respectfully follow we are of opinion that there is no merit in departmental appeal and hence it is dismissed. *** INCOME TAX OFFICER v. SMT. SHUKBA MUKHERJEE