Vakalat authority affirmed to cover applications under section 66(1), so representative could sign and file reference application.

Whether a vakalat authorising counsel in rectification proceedings extended to signing and presenting an application for reference under section 66(1) was resolved by construing the vakalat's comprehensive language to include "all proceedings connected with" the rectification order; the legal principle applied is that an application under section 66(1) may be signed by the assessee or an authorised representative and a mandatary's authority extends to connected proceedings when expressly conferred, and therefore the application was held effective and the Tribunal's limitation-based rejection was unsustainable.

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Issues: Whether a vakalat executed by the assessee in rectification proceedings, containing authority to conduct "all proceedings connected with the same or any order passed therein," authorised the advocate to sign and present an application for reference under section 66(1) of the Income-tax Act, and whether the Tribunal's rejection of the application as barred by limitation was sustainable.

Analysis: The vakalat-form authorised the advocate to appear for the assessee "to conduct and prosecute (or defend) the same and all proceedings that may be taken in respect of any application connected with the same or any decree or order passed therein." The application for reference under section 66(1) arises out of and is connected with the rectification proceedings and the Tribunal's order. Prior authorities establish that an application under section 66(1) need only bear the signature of the assessee or an authorised representative. Given the comprehensive language of the vakalat, the mandate extended to proceedings connected with the rectification order, and therefore encompassed the application for reference. The Tribunal's conclusion that the advocate lacked authority because the vakalat was filed only in the rectification proceeding fails when the vakalat's express terms are construed to include connected proceedings.

Conclusion: The vakalat granted the advocate authority to sign and present the application for reference under section 66(1); the Tribunal's order rejecting the application as barred by limitation is unsustainable. The application is to be treated as filed within time and the Tribunal directed to dispose of it in accordance with law.

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