(1.) HEARD Mr. J. P. Shah, learned advocate for the appellant, and Mr. B.B. Naik, learned standing counsel for the respondent.
(2.) ADMIT .
(3.) THE assessment year 1990 -91 and the relevant accounting period is financial year ended on 31 -3 -1990. In the assessment order, framed under section 143(3) read with section 147 of the Income Tax Act, 1961 (the Act), the assessing officer has recorded as under :