HENRI ISIDORE Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) AT the instance of the assessee, the Income-tax Appellate Tribunal, Madras, has stated a case and referred the following question of law under section 256(1) of the Income-tax Act, 1961, for the assessment year 1977-78, for the opinion of this court :

(2.) THE facts leading to the reference are as under :

(3.) THIRDLY, the question whether the order can be rectified under the provisions of section 154 of the Act, has to be tested on the language employed under section 154 of the Act and the condition prescribed under section 154 of the Act. If the ingredients found in section 154 of the Act are satisfied we are of the opinion that the order passed by the Income-tax Officer under section 271 of the Act is also liable to be rectified provided, other conditions found in section 154 of the Act are satisfied.