1986 (12) TMI 53

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....ment made by the ITO on 26th March, 1985, after initiating proceedings by issuing notice under s. 148 of the IT Act, 1961. 2. The assessee is a firm and the accounting period relevant to the assessment year under appeal ended on 31st March, 1976. It filed a return of income on 31st March, 1977, which in its various columns showed the assessment year of the return to be 1977-78, but the annexure....

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....val submissions and looked into the order of the CIT(A). The facts of the case are so clear that we find that the view taken by the CIT(A) is quite reasonable and correct and there is no substance in the appeal of the Revenue. It is an admitted position that the return filed on 31st March, 1977, mentioning on the face of it asst. yr. 1977-78, etc. was accompanied by statements of accounts for the ....

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....sst. yr. 1976-77 on 23rd Feb., 1980. These facts clearly show that the ITO was aware that there was mistake in indicating the assessment year in the body of the return and the correct assessment year was 1976-77. Despite this the ITO chose to ignore the return and initiate action under s. 147 on 5th July, 1980, and to issue notice under s. 148 on 7th July, 1980. The facts are of eloquent to bring ....