Change of previous year and section 41(1) liability remained unresolved pending related proceedings; appeal disposed of under Article 136.

The Court declined to express any opinion on the revocation of the assessee's change of previous year, noting that later assessments had proceeded on the calendar year basis and that disturbing them after many years would cause practical hardship; the appeal was disposed of under Article 136 without deciding the substantive issue. On liability under section 41(1), the Court held that no cessation of liability can be assumed while the relevant appeal and related Tribunal proceedings remain pending, and the assessment may be adjusted once those proceedings are finally resolved.

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Outcome: The civil appeal was disposed of without any final adjudication on the first question, the third question was not pressed, and the second question was left to depend on the outcome of pending proceedings.

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