S.N. Phukan, J.— This is a reference under section 256(1) of the Income Tax Act, 1961 for short, 'the Act' on the prayer of the Revenue. The following question has been referred to this Court for opinion. “ Whether on the facts and in the circumstances of the case the Tribunal was justified in law in deciding that a step-child does not come within the purview of Section 64(1) (iii) when Section 2(15A) of the Income-Tax Act, 1961, clearly defines “child” in relation to an individual includes a stepchild and an adopted child of that individual?” 2. The present reference relates to the assessment year 1979-80. The assessee was a partner of the firm in which minor step-daughter, namely, the daughter of her husband for some other wife was admitted to the benefit of the said firm. The Income Tax Officer included the minor's share in the total income of the assessee. On appeal, the Appellate, Assistant Commissioner ordered that the said share could not be included because section 64(1) (iii) of the Income Tax Act would not cover the case of a step child. A second appeal was filed by the department and the Tribunal after discussing the relevant provisions of various Acts confirmed the decision of the Appellate Assistant Commissioner holding that section 64 (1) (iii) did not apply to a step child. 3. We have heard Mr. Senapati, learned counsel for the revenue and Mr. A.K. Saraf, learned counsel for the assessee. 4. To consider the matter, the following provisions of the Act are rele­vant. Clause (15A) of section 2 of the Act defines 'child' which runs as follows: "(15A) "child", in relation to an individual, includes a step-child and an adopted child of that individual; " It may be stated that this clause was inserted by Tax Laws (Amendment) Act, 1975 which came into force from 1.4.1976. The above clause was renumbered as "15B" by an amendment in 1987 which came into force with effect from 1.4. 1988. Clause (iii) of sub-section (1) of section 64 of the Act runs as follows :- ''64 (1). In computing the total income of any individual, there shall be included all such income as arises directly or indirectly ............ The above clause was renumbered as "15B" by an amendment in 1987 which came into force with effect from 1.4. 1988. Clause (iii) of sub-section (1) of section 64 of the Act runs as follows :- ''64 (1). In computing the total income of any individual, there shall be included all such income as arises directly or indirectly ............ iii) to a minor child of such individual from the admission of the minor to the benefits of partnership in a firm ;" Explanation-I of said sub-section (1) of section 64 of the Act runs as follows : "l.-[For the purposes of clause (i)] the individual, in computing whose total income the income referred to in that clause is to be included, shall be the husband or wife whose total income (excluding the income referred to in that clause) is greater; and, for the purposes of clause (iii), the income of the minor child from the partnership shall be included in the income of that parent whose total income (excluding the income referred to in that clause) is greater ; and where any such income is once included in the total income of either spouse or parent, any such income arising in any succeeding year shall not be included in the total income of the other spouse or parent unless the Income-tax Officer is satisfied, after giving that spouse or parent an opportunity of being heard, that it in necessay so to do ......" 5. According to Mr. Senapati, in view of the definition of the child which includes a step-child the Tribunal erred in law in ignoring this defini­tion. Learned counsel has submitted that in a taxing statute analogies play no part. Whether it is a charge, allowance of a deduction or exemption from a charge the direct terms of the statutory provisions will have to be followed. In support learned counsel has placed reliance in a decision of the Madras High Court in Alagappa Chettiar vs. Controller of Estate Duty, reported in (1966) 60 ITR 289. Learned counsel has further submitted that when a legisl­ature has given a special meaning to a particular word in a particular statute then that meaning has to be given to that word and in support our, attention has been drawn to the decision of the Allahabad High Court in Commissi­oner of Income-tax vs. J.K. Cotton Spinning reported, (1987) 164 ITR 18 6. Mr. Mr. Saraf has rightly stated that on the above proposition of law there cannot be any dispute, However, according to the learned counsel the definition of a "child" as stated above is not applicable to section 64 more particularly in view of the explanation 1 to said section of 64. According to learned counsel the word 'parent' occurring in explanation 1 is the crux of the matter and 'parent' will include only the natural parent. According to learned counsel as the word 'parent' has not been defined in the Act the Tribunal was justified in taking aid of the provisions of Hindu Adoption and Maintenance Act, 1956 and Hindu Minority and Guardianship Act, 1956. In this connection, learned counsel has drawn our attention to the decision of the Goa Bench of Bombay High Court in Leukoplast (India) Ltd. vs. State of Goa & others,(1988)171 ITR 180 wherein it was held that generally. a definition given to a word or an expression in a particular Act or statute cannot be utilised for the interpretation of a similar word or expression occurring in a different Act or statute, but this is not an absolute principle of law and in a given case, the definition given in a particular statute, not being repugnant, may be used to construe and interpret the same expression in another statute. 7. According to learned counsel for the assessee the main object Of explanation 1 to sub-section (1) of section 64 is to ensure that income of a minor child in a partnership shall be included only in respect of the income of his natural parent. Learned counsel has given some illustration such as a child may have two or more step mother and his natural mother may also be alive and in that case the income has to be included only in the income of natural mother as otherwise it would be difficult for the revenue to ascertain as to which step-mother the income of the minor should be included. 8. Regarding explanation 1 we are unable to accept the submission of the learned counsel for the assessee. In our opinion the object of this explanation is to determine to whose income, whether the father or mother, the income of the child has to be included. 8. Regarding explanation 1 we are unable to accept the submission of the learned counsel for the assessee. In our opinion the object of this explanation is to determine to whose income, whether the father or mother, the income of the child has to be included. We may also add that this explanation does not nullify the definition of child in the Act or the said definition of "child'' is repugnant to above explanation 1. We may also add that as the expression 'parent' has not defined Mr. Saraf has drawn our attention to the dictionary meaning of the said word. But in our opinion the clear meaning of the child has been provided in the Act and we need not refer to the dictionary meaning of the word 'parent'. 9. For what has been stated above, we are of the opinion that the step­child would come within the purview of section 64 (1) (iii) of the Act in view of clear definition of 'child' vide section 2 (15A) of the Act. In the result, the question is answered in favour of the Revenue and against the assessee.