TMI Blog1991 (8) TMI 60X X X X Extracts X X X X X X X X Extracts X X X X ..... s court: " 1. Whether, on the facts and in the circumstances of the case, the provisions of section 144B of the Income-tax Act, 1961, pertained to the branch of procedural law and the same applied to all income-tax proceedings pending on January 1, 1976, irrespective of the assessment year to which those proceedings related ? 2. Whether, on the facts and in the circumstances of the case, the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Commissioner of Income-tax (Appeals) did not accept the valuation of the property as on January 1, 1954, as put by the assessee. Second appeals were filed to the Tribunal and it was, inter alia, urged that the proceedings for the years in question under section 144B of the Act were illegal and void inasmuch as section 144B of the Act was substantive law and did not apply as the same was not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... even in relation to the assessment years prior to January 1, 1976, with regard to those assessments which were not complete. (See Sonai River Tea Co. Ltd. v. CIT [1990] 182 ITR 162 (Gauhati) ; Banarsidas Bhanot and Sons v. CIT [1981] 129 ITR 488 (MP) ; K. U. Srinivasa Rao v. CWT [1985] 152 ITR 128 (AP); Imam (H. S.) v. CIT [1988] 171 ITR 214 (AP) and CIT v. Damoh Co-operative Marketing Society Ltd ..... X X X X Extracts X X X X X X X X Extracts X X X X
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