1993 (2) TMI 58

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....he assessee's appeal before the Appellate Assistant Commissioner against the order of assessment for the assessment year 1968-69 was disposed of by the Appellate Assistant Commissioner on May 30, 1972. By an application dated May 29, 1976, which was received by the Appellate Assistant Commissioner on June 1, 1976, the assessee applied for rectification of that order by granting deduction of surtax....

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.... 154 of the Act on the same ?" The Tribunal has referred the said question to this court for its opinion. What is contended by learned counsel for the assessee is that, if the Appellate Assistant Commissioner wanted to reject the assessee's application on the ground of limitation, then the assessee should have been given an opportunity of satisfying him that the application was not barred by....