RAYON SILK MILLS Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THE Tribunal, Ahmedabad Bench 'A' at the instance of the assessee has referred the following two questions of law arising out of its order in ITA No. 420/Ahd/79 relating to the asst. year 1974 75, for the decision of this Court :

(2.) THE ITO had completed assessment under S. 143(3) of the Act for the asst. year 1974 75 in the case of the assessee, a registered firm on 25th Jan., 1977. On 15th Dec., 1978 the CIT, Rajkot issued notice under S. 263 of the IT Act stating that on going through the case records of the IT assessment proceedings of the assessee for the asst. year 1974 75 it was noticed that the assessment made by the ITO on 25th Jan., 1977 is erroneous and is prejudicial to the interests of the Revenue on the following grounds :

(3.) WE have heard learned counsel for the parties.