TMI Blog1977 (4) TMI 45X X X X Extracts X X X X X X X X Extracts X X X X ..... o charge interest under s. 217 (A) IT Act at the time of the completion of assessment is a mistake apparent from the record in a case where ITO sat still in the return of income for over a year. 2. 1971-72 is the assessment year concerned. The assessee is registered firm. It field the original return on 22nd July, 1971 and the revised return on 10th Nov., 1973. The ITO took up the assessment on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... amendment but the appeal failed. Hence this second appeal. 4.The assessee's argument before us was that as the assessment was not taken up by the ITO for about two years after the receipt of the original return, the failure to complete the assessment within a year could not be attributed to it irrespective of the fact of filing of revised return in 1973 and that, therefore, the case clearly fell ..... X X X X Extracts X X X X X X X X Extracts X X X X
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