1996 (7) TMI 52

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....er section 256(2) of the Income-tax Act, 1961, praying for a direction to the Income-tax Appellate Tribunal, Cochin Bench, to refer the following questions of law for decision of this court : "1. Whether, on the facts and in the circumstances of the case and considering a search was conducted on the premises of the assessee under section 132 of the Income-tax Act, is the Appellate Tribunal right ....

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....s rejected by the Income-tax Officer. On appeal the Commissioner of Income-tax (Appeals) has concurred with the view of the assessing authority that the benefits of the Amnesty Scheme could not be extended to the assessees for the aforesaid years. On further appeal, the Income-tax Appellate Tribunal came to the conclusion that the revised returns filed by the assessees were to be considered as ret....

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....ubsequent to the search cannot be considered to be a return under the Amnesty Scheme. Learned standing counsel for the Revenue brought to our notice "the Amnesty circulars" issued by the Central Board of Direct Taxes (No. 441, (F. No. 225/86/85-IT(A-II), dated November 15, 1985). Subsequent to the proclamation of the Amnesty Scheme, certain clarifications were issued in relation thereto. While rea....