COMMISSIONER OF INCOME TAX Vs. HIND WIRE INDUSTRIES LTD
LAWS(CAL)-1993-3-25
HIGH COURT OF CALCUTTA
Decided on March 24,1993

COMMISSIONER OF INCOME-TAX Appellant
VERSUS
HIND WIRE INDUSTRIES LTD. Respondents

JUDGEMENT

Ajit K.Sengupta, J. - (1.) In this reference under Section 256(1) of the Income-tax Act, 1961, the Tribunal has referred the following question at the instance of the Revenue relevant to the assessment years 1976-77 to 1980-81 : "On the facts and in the circumstances of the case whether the Tribunal is justified in holding that the mistake which the assessee seeks to get rectified has occurred in the set of rectification orders passed under Section 154 of the Income-tax Act, 1961, on July 12, 1982, and that date should be taken into account for purposes of computing the period of limitation ?"
(2.) As the question indicates there was a set of rectification orders in respect of the assessment years and a further mistake occurring in such rectification orders is sought to be rectified by the assessee which the Revenue contends against on the ground that for computing the period of limitation for rectification the date of the original order is relevant and not the date on which the rectification orders were passed.
(3.) The following table abstracts the various dates which have a bearing on the issue involved : JUDGEMENT_274_ITR202_1993Html1.htm;


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