(1.) RELEVANT to the asst. yr. 1979 -80, the following question has been referred for our opinion :
(2.) AS the question itself suggests that the amendment to s. 263(1) of the IT Act, 1961 ('Act') was brought w.e.f. 1st
(3.) WE have seen the statute which is printed in (1984) 43 CTR (TLT) 1 : (1984) 149 ITR (St) 97. Sec. 47 of the 1984 Amendment Act reads as under :