1977 (12) TMI 24

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....ving heard counsel for the parties, we are satisfied that the following questions of law do arise from out of the appellate order of the Tribunal: "(1) Whether, on the facts and in the circumstances of the case, the Tribunal was legally correct in holding that two assessments should be made separately for the two periods: April 1, 1971, to October 31, 1971, and November 1, 1971, to March 31, 1972....

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....he Appellate Tribunal, arises. Shri Ashok Gupta, learned counsel for the Commissioner of Income-tax, has invited our attention to a Full Bench decision of the Andhra Pradesh High Court, in the case of Additional Commissioner of Income-tax v. Visakha Flour Mills [1977] 108 ITR 466, which, after considering one Full Bench decision of this court, has taken a view contrary to that taken by this court....