Shyamal Kumar Sen, J. - (1.) The assessee, Messrs. India Ferro Alloy Industry (Private) Ltd., is a resident company. The years of assessment involved are 1956-57 to 1958-59. The Income-tax Officer completed the reassessments under Section 147(a) of the Act for all these three years on October 15, 1980. The assessee filed appeals against the said assessment orders before the Commissioner of Income-tax (Appeals) who disposed of the appeals by a common order dated January 24, 1985. One of the grounds taken in those appeals was that the assessments were barred by limitation under Section 153(2) read with Clause (ii) of Explanation 1. The Commissioner of Income-tax (Appeals) held that the assessments were not barred by limitation.
(2.) The assessee came up in appeal before the Tribunal. The Tribunal did not accept the contentions and reasonings advanced on behalf of the assessee and held that the assessments were completed well within time.
(3.) At the instance of the assessee, the following question of law was referred to this court by the Tribunal : "Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the assessments for the assessment years 1956-57 to 1958-59 were not barred by limitation ?";