9911796707
TMI Blog2006 (11) TMI 196X X X X Extracts X X X X X X X X Extracts X X X X ..... eferred for the opinion of this court by the Income-tax Appellate Tribunal, Amritsar Bench, Amritsar, arising out of its order dated April 30, 1990, passed in I. T. A. Nos. 608 to 611/ASR./1990, in respect of the assessment year 1977-78. "Whether, on the facts and in the circumstance of the case, the Tribunal was right in law in interpreting the word 'reduction' and 'enhancement' as provided in s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... which the order in the case of the firm was passed was beyond limitation. The Commissioner of Income-tax (Appeals) accepted this objection which view was upheld by the Tribunal rejecting the objection on behalf of the Revenue that finalisation of the assessment of the firm by the Commissioner of Income-tax (Appeals) was on August 17, 1987, and limitation should be counted from that date. The Comm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the material time was to the following effect : '155. (1) where in respect of any completed assessment of a partner in a firm it is found : (a) on the assessment or reassessment of the firm, or (b) on any reduction or enhancement made in the income of the firm under this section, section 154, section 250, section 254, section 260, section 262, section 263 or section 264, that the share of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s any reduction or enhancement made in the income of the firm under sections 155, 154, section 250, or section 254, 260, 262, 263 or section 264 then within four years from the end of the financial year in which such order was passed by the appellate or revisionary authority, etc., was passed. The extended jurisdiction under clause (b) of sub-section (1) of section 155 is available only in such ca ..... X X X X Extracts X X X X X X X X Extracts X X X X
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