1992 (10) TMI 5

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....-tax, Nagpur, under section 256(1) of the Income-tax Act, 1961 (" the I. T. Act "), on the following two questions : " 1. Whether, on the facts and circumstances of the case, the assessee-firm was entitled to deduction under section 80HH for the assessment years 1981-82 and 1982-83 and section 80J deduction for the assessment year 1982-83? 2. Whether, on the facts and circumstances of the case, ....

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....haraja and Co. [1980] 121 ITR 212 which was the only decision then operating in the field. The assessee had preferred an appeal before the Commissioner of Income-tax (Appeals) for the assessment year 1981-82 on certain other issues. For the assessment year 1982-83, the Income-tax Officer again allowed deduction under section 80HH. For branches in backward areas deduction was allowed for the first ....

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....for the subsequent years. That in view of the merger of the Income-tax Officer's order for the assessment year 1981-82 in appeal, revisional jurisdiction could not be exercised is a settled position having been concluded against the Revenue by several decisions of this court including CIT v. P. Muncherji and Co. [1987] 167 ITR 671. The Calcutta High Court in the case of Russell Properties Pvt. L....