1986 (1) TMI 90

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....titution of India by the assessee for quashing the assessment order dated November 8, 1979 (annexure I to the writ petition), and the order dated March 20, 1982, passed by the Commissioner of Income-tax under section 264 of the Income-tax Act, 1961 (for short " the Act of 1961 "), which has been filed in original. The short question for consideration in this case is whether the Income-tax Officer ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... was allowed on the condition that income of the period from Diwali, 1975, to March 31, 1977, would be assessed in the assessment year 1977-78. The order-sheet also showed that the said condition was accepted by the assessee. Thereupon, the Income-tax Officer made the assessment for the entire period in a single assessment order pertaining to the assessment year 1977-78. The legal question that ha....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....previous year (twelve months) could have been legally made. Sri R. V. Gupta, the learned counsel for the petitioner, further contended that the firms were reconstituted thrice with different combinations and the petitioner has been agitating the question that as there were three separate entities, one single assessment for the entire period should not have been made on them and each entity shou....