1980 (10) TMI 22

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....ered by B. S. DHILLON J.-This order will dispose of I.T.C. No. 57 of 1975 and I.T.C. No. 58 of 1975. The brief relevant facts are that the assessee in the course of the original assessment proceedings did not disclose that he had constructed four more floors to the already existing multi-storeyed building at P-II, New Howrah Bridge Approach Road, Calcutta. Later on, when the ITO came to know....

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....on and to decide whether any addition can be made on account of income from these floors. The assessee made a reference application to the Appellate Tribunal with a prayer that the following common question of law be referred to the High. Court at Calcutta for its opinion : " Whether, on the facts and in the circumstances of the case, the proceedings under section 147 of the Act, 1961, could be....

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....ven complete till the assessment year 1961-62 and were not ready for occupation. It has been contended that even though the addition of Rs. 30,000 was made in the assessment proceedings for 1961-62 for the income from the said floors, yet there was no material to hold that the said floors had been completely constructed and were ready for occupation during the assessment year 1958-59. It has thus ....