1993 (2) TMI 58

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....te 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 paid by the assessee for the relevant ....

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....nal 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 limitation. He further submitted that the as....