1979 (7) TMI 124

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....ch he accepted the appeal of the assessee allowing him registration for the two assessment years in question. The sole ground urged in these appeals is that the declaration in Form No. 12 should have been filed by the assessee on the 30th June, 1973 and 30th June, 1974 respectively whereas both of them were actually filed on 12th Jan., 1976 and were, therefore, delayed by more than 30 and 18 month....

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.... thereof is that the assessee firm is assessed as URF and the question of status can certainly be taken up in the appeal against the order passed under s. 143(3) of the IT Act. The Allahabad High Court itself has recently considered the matter in ITO vs. Vinod Krishna Som Prakash(2), wherein the AAC has similarly entertained an appeal and set aside the ITO's order of refusal and upon a reference, ....