https://www.taxtmi.com/caselaws?id=39693 The High Court of Allahabad dismissed a petition by a private limited company seeking rebate under section 84 of the Income-tax Act for the assessment year 1963-64. The court emphasized the mandatory nature of making the claim during assessment proceedings, highlighting the specific conditions required for such relief. The court rejected the argument that a claim under the Super Profits Tax Act extends to the Income-tax Act, emphasizing the distinct nature of the two acts. Additionally, the court noted the limitation of relief to 6% of capital employed and the necessity of specific computation as per rule 19, which was lacking in the case. The court also clarified that section 154 cannot rectify the absence of a valid claim during assessment proceedings. Ultimately, the petition was dismissed for failing to meet the necessary requirements and absence of a valid claim during assessment proceedings. en-us Sat, 23 Sep 1972 00:00:00 +0530 Mon, 19 Apr 2010 16:50:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39693 The High Court of Allahabad dismissed a petition by a private limited company seeking rebate under section 84 of the Income-tax Act for the assessment year 1963-64. The court emphasized the mandatory nature of making the claim during assessment proceedings, highlighting the specific conditions required for such relief. The court rejected the argument that a claim under the Super Profits Tax Act extends to the Income-tax Act, emphasizing the distinct nature of the two acts. Additionally, the court noted the limitation of relief to 6% of capital employed and the necessity of specific computation as per rule 19, which was lacking in the case. The court also clarified that section 154 cannot rectify the absence of a valid claim during assessment proceedings. Ultimately, the petition was dismissed for failing to meet the necessary requirements and absence of a valid claim during assessment proceedings. Case-Laws Income Tax Sat, 23 Sep 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39693