Dipak Kumar Sen, J. - (1.) In this reference at the instance of the Commissioner of Income-tax, West Bengal-I, the Tribunal has been directed under Section 256(2) of the Income-tax Act, 1961, to send up a statement in respect of the following two questions : "1. Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that there was no mistake apparent from the record regarding the allowance of Rs. 61,163 as wealth-tax and that accordingly the order of rectification passed by the Income-tax Officer in respect thereof was not justified in law ? Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the omission to charge interest under Section 18A(7) of the Income-tax Act could not be rectified under Section 154 of the Income-tax Act, 1961, and in deleting the charge of Rs. 7,173.63 made by the Income-tax Officer ?"
(2.) The facts found or admitted as will appear from the statement of the case and the annexures thereto may briefly be noted.
(3.) The assessee is General Electric Co. of India Ltd., Calcutta. At the relevant time, that is, during the assessment year 1959-60, the assessee was known as the Associated Electric Industries (India) Private Ltd. Subsequently, on and from the 29th March, 1967, the assessee first became a public limited company and thereafter suffered a merger pursuant to an order of this court dated the 27th February, 1969.;