1994 (10) TMI 19

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....978, the undertaking of the company, namely, the Hindustan Tractors Ltd., and its right, title and interest in relation to its undertakings stood transferred and vested in the Central Government under section 3 of the Act. As per the provisions of section 4 of the Act, the whole assets, rights, leaseholds, powers, authorities and privileges, and all the property, movable and immovable, including lands, buildings, workshops, stores, instruments, machinery and equipment, bank balances, cash balances, cash on hand, reserve funds, investments and book debts and all other rights and interests in, or arising out of, such property as were immediately before the appointed day in the ownership, possession, power or control of the company, whether wi....

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....eviewing the order under section 264 of the Act. The Commissioner of Income-tax, Baroda, by taking into consideration the past history of the assessee-company about late filing of returns or not responding to notices under section 154 of the Act timely, refused to condone the delay and entertain the revision. Hence, the petitioner approached this court. The petitioner is a public undertaking and discharging its functions under a statute in respect of the undertakings vested in by the order of the Central Government. Its obligation to discharge liabilities relating to the period prior to the appointed day incurred by the company to which the undertaking was earlier belonging, is governed by the statute and the mere fact that because of so....