2006 (3) TMI 61

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.... P-10 whereunder the Commissioner of Income-tax has rejected the revision petition filed by both the petitioners filed under section 264 of the Income-tax Act, 1961, against income-tax assessment for 1993-94. 2 The petitioners are the partners of a firm by name M/s. Thoppil Finance. The income returned by the petitioners for the assessment year 1993-94 was towards remuneration and salary receiv....

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....e. In short, the petitioners' grievance is against the double assessment of the same income. 3 The senior standing counsel appearing for the Revenue contended that the Commissioner has no authority to interfere with the decision of the Settlement Commission and the petitioners' assessments were made based on the returns filed. Moreover, he justified the finding of the Commissioner that there is....