(1.) HEARD counsel for the parties.
(2.) THIS appeal is filed against the judgment dated May 29, 1991, in O. P. No. 4558 of 1991 (see , [1992]193ITR772(Ker) ). In the original petition, the assessee challenged, exhibit P-6 order, dated October 31, 1990, passed by the Commissioner of Income-tax, under Section 264 of the Income-tax Act, 1961 (for short "the Act").
(3.) FORTIFIED by the appellate order, the assessee filed a revision under Section 264 of the Act before the Commissioner of Income-tax. By the impugned order dated October 31, 1990 (exhibit P-6), the Commissioner of Income-tax held as under :