TMI Blog2005 (12) TMI 69X X X X Extracts X X X X X X X X Extracts X X X X ..... on before the Commissioner of Income-tax under section 264 of the Income-tax Act. The said revision came to be rejected – held that revision could not be rejected only on ground of delay – further, held therein that the Taxation Laws (Amendment) Act, 1984 is procedural in nature and, therefore, it will apply to all the pending actions. This being so, sub-section (1A) which was introduced in secti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion filed by the petitioner. The facts leading to this revision and the said order dated January 30, 1992 are as follows: For the assessment year 1982-83, the petitioner filed a return of income on July 31, 1982, declaring income of Rs. 56,53,380. The assessment order was passed on January 31, 1985, determining the income at Rs. 71,91,717 by making various disallowances. As per the assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ficer issued a refund order for Rs. 18,36,801 consisting of Rs. 15,45,081 being refund of tax and Rs. 2,91,720 towards interest under section 214. The petitioner made a representation on April 1, 1987, to the Assessing Officer seeking the details of the refund so as to know how the interest was calculated. Reminders were sent and finally on December 30, 1988, the Assessing Officer gave the break ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t from April 1, 1985, and not in respect of the year in question. Mr. Mehta, learned counsel appearing for the petitioner, has drawn our attention to a Division Bench judgment of this court in the case of CIT v. Saswad Mali Sugar Factory Ltd. reported in [2001] 249 ITR 756. The Division Bench has held therein that the Taxation Laws (Amendment) Act, 1984 is procedural in nature and, therefore, it w ..... X X X X Extracts X X X X X X X X Extracts X X X X
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