Dipak Kumar Sen, J. - (1.) The assessee prays for a certificate that he has a fit case to prefer an appeal to the Supreme Court against a judgment of this court in CIT v. Assam Oil Co. Ltd. [1982] 133 ITR 204. Learned advocate for the assessee has submitted that the following two substantial questions of general importance arise from the judgment: " (a) Whether a decision of a High Court can constitute information within the meaning of Section 147(b) of the Income-tax Act, 1961, when the same is subsequently reversed by the Supreme Court ? (b) Whether in a reassessment under the said Section 147(b), the Income-tax Officer can cover escapement of assessment not related to or connected with the information on which such reopening had been made or with any subsequent information which might have come into his possession prior to reassessment?".
(2.) In our view, the said questions are of general importance. Decisions of different High Courts relevant to the questions were cited by learned advocate for the assessee as noted hereafter: (a) AL. VR. Veerappa Chettiar v. CIT, (b) Parshuram Pottery Works Co. Ltd. v. D.R. Trivedi, WTO [1975] 100 ITR 651 (Guj); (c) Karamchand Premchand Pvt. Ltd. v. CIT, [1975] 101 ITR 46 (Guj); (d) Madras Auto Service v. ITO, (e) New Kaiser-I-Hind Spinning & Weaving Co. Ltd. (In liquidation) v. CIT, [1977] 107 ITR 760 (Bom) and (f) R. Kuppuswamy Mudaliar & Sons v. Board of Revenue (Commercial Taxes), [1980] 45 STC 152 (Mad).
(3.) The pronouncements in the above decisions do not appear to be uniform.;