1987 (11) TMI 17

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....dent No.1 under section 277 of the Income-tax Act, 1961 ("the Act" in short), against the petitioner, for having filed a return of income for the assessment year 1976-77, declaring his income at Rs. 31,820. The allegation is that in another firm known as Satinder Singh Sarbjit Singh, two minor sons of the petitioner, were admitted to the benefits of the partnership and both the sons had earned pro....

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....Commissioner (PW-2). Thereafter, the evidence was closed and documents, exhibits PG and PH, were tendered in evidence. At the time of framing the charge, it was brought to the notice of the trial court that the order of respondent No. 1, directing the inclusion of profits of the minors in the return of the petitioner, was set aside by the Appellate Tribunal, vide its order dated July 29, 1982, whe....

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.... Department on a point of law cannot be regarded as opinion" within the meaning of section 147(b) of the Income-tax Act, 1961. In the order dated July 29, 1982 (annexure p-3), decided by the Income-tax Appellate Tribunal, it was held that section 64(1)(iii) of the said Act came on the statute when sub-section (1) of section 64 was substituted by section 13 of the Taxation Laws (Amendment') Act, 19....