1981 (6) TMI 60

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....No. 11/30/78-79/SPR, whereby. inter-alia, he directed the ITO to frame two separate assessments for the period from1st April, 1975to31st March, 1976. 2. The facts relating to the present appeal are briefly stated as follows : 3.The assessee is a partnership firm, namely M/s Sant Motor Stores,Ambala Road,Saharanpur. The asst. yr. is 1976-77. The previous year ended by31st March, 1976. From1st....

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....was shown whereas in the second return an income of only Rs. 18,080 was shown. The assessee firm contended that the old firm discontinued its business and the new firm conducted the business from1st Oct., 1976. The new firm is quite different from the old and so two assessments must be made. The ITO granted registration both to the old firm and to the new firm during the asst. yr. 1976-77. However....

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....to frame another assessment on the reconstituted firm from 1st Oct., 1975 to 31st March, 1976 following decision reported in 1975 CTR (All) 22: (1977) 106 ITR 342 (All), CIT vs. Shiv Shankar Lal Ram Nath. As against the said decision of the CIT (Appeals) the present appeal is preferred before this Tribunal and thus the matter stands for our consideration. Virtually, the same arguments which were a....