2007 (2) TMI 580

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....l, Delhi Bench " D" in I. T. A. No. 558/Del/ 2003 relevant for the block assessment period April 1, 1989, to July 27, 1999. The block assessment in respect of the assessee under section 158BC of the Income-tax Act, 1961, was completed on August 31, 2001. At that time, surcharge was not levied. Subsequently, by an order dated January 7, 2003, the Assessing Officer rectified the block assessme....

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..... Against the order of the Commissioner (Appeals), the Revenue preferred an appeal before the Tribunal. The Tribunal held, and in our view rightly, that apart from the fact that the issue is debatable and no such order could have been passed in rectification proceedings under section 154 of the Act, even on the merits the proviso to section 113 of the Act did not have any retroactive effect. The p....