(1.) THIS is a reference under section 66(1) of the Income-tax Act.
(2.) THE question which has been referred to the court for opinion is :
(3.) THERE is another way of looking at the matter. This is a case to which the provisions of section 28(1)(c) were held to be attracted. Under section 34(2) as it stood at the time, it was provided that in a case to which the provisions of section 28(1)(c) were attracted assessment could be completed within eight years. Thus even without reference to section 34(1)(a) reassessment can be justified as an assessment under section 23.