2013 (7) TMI 734

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....mar Mittal,J. 1. The petitioner-assessee has approached this Court under Article 226 of the Constitution of India impugning order dated 27.3.1997, Annexure P.5 passed by the Commissioner of Income Tax, Patiala (in short, "the CIT") under section 264 of the Income Tax Act, 1961 (in short, "the Act"). 2. Briefly, the facts as narrated in the petition may be noticed. The petitioner firm is carrying....

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.... the said date and was available even during the assessment year in question as well i.e. 1983-84. The petition under Section 264 of the Act having been rejected by respondent No.1, the petitioner has approached this Court by way of present petition. 4. According to the learned counsel, the amount of Rs.5,90,000/- disclosed under Amnesty Scheme for the assessment years 1976-77 and 1977-78 was hel....

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....able in its books of account. The said amount was also held to be available with the petitioner relating to the assessment year 1984-85. It was pointed out that in Income Tax Case No.35 of 1999 relating to assessment year 1984-85, prayer of the revenue seeking directions to the Tribunal to refer question of law claimed by it was declined by this Court. As a necessary corollary, amount of Rs.5,90,0....