28 December 2008
It is a very complicated issue covering several aspects where it can be considered & not. Check the detailed provision of 2(22)e & if you have any query mail me on cbambani@yahoo.co.in I will clarify your doubts & queries thereon If you are asking this of academic interest refer the section as told, & if you are facing some case regarding the prov of 2(22)e then pls be frank to tell me than I can advise you as per your case facts