1977 (1) TMI 13

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....1 : " 1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that the period of limitation under section 154 of the Income-tax Act, 1961, should be computed from the Order of the Income-tax Officer under section 49A of the Indian Income-tax Act, 1922, dated February 22, 1961, and not from his order dated September 4, 1963, under section 154 of....

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....ry 22, 1961, under section 49A of the Act granting certain reliefs to the assessee under the Agreement for Avoidance of Double Taxation between India and Pakistan. On September 4, 1963, the Income-tax Officer passed an order under section 154 by which he modified the order dated February 22, 1961. In the assessment year 1955-56, the Income-tax Officer passed his order on March 30, 1961, granting ....