TMI Blog1986 (1) TMI 90X X X X Extracts X X X X X X X X Extracts X X X X ..... 1979 (annexure I to the writ petition), and the order dated March 20, 1982, passed by the Commissioner of Income-tax under section 264 of the Income-tax Act, 1961 (for short " the Act of 1961 "), which has been filed in original. The short question for consideration in this case is whether the Income-tax Officer was justified in making a single assessment for 19(17?) months by the order dated Nove ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1977, would be assessed in the assessment year 1977-78. The order-sheet also showed that the said condition was accepted by the assessee. Thereupon, the Income-tax Officer made the assessment for the entire period in a single assessment order pertaining to the assessment year 1977-78. The legal question that has been raised by the assessee-petitioner is whether an assessment for the period exceedi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed counsel for the petitioner, further contended that the firms were reconstituted thrice with different combinations and the petitioner has been agitating the question that as there were three separate entities, one single assessment for the entire period should not have been made on them and each entity should have been assessed for its own broken period. He further says that the question is sti ..... X X X X Extracts X X X X X X X X Extracts X X X X
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