TMI Blog1982 (5) TMI 40X X X X Extracts X X X X X X X X Extracts X X X X ..... 3-74, the assessee failed to put up any claim under s. 80J of the I.T. Act before the ITO. In appeal before the AAC, the assessee claimed benefit under s. 80J on the ground that it was a newly constituted firm and was entitled to the benefit of that provision. The AAC rejected the claim on the reasoning that no relief under s. 80J was claimed either in the returns or in the assessment proceedings ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ther in the returns or before the Income-tax Officer during the course of the assessment proceedings ? " It may be noted that by the Finance (No. 2) Act, 1967, s. 80J was inserted in place of s. 84, which was deleted. The basis of the Tribunal's order is the decision of the Gujarat High Court referred to above. That decision was taken up to the Supreme Court in .Addl. CIT v. Gurjargravures P. Lt ..... X X X X Extracts X X X X X X X X Extracts X X X X
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