(1.) Although the Constitutional validity of Sec. 143 (1)(a) of the Income Tax Act, 1961 ('the Act' for short) is challenged in this petition, the learned counsel for the petitioners has given up the issue relating to the constitutional validity and has restricted his arguments to challenge the intimation issued u/s. 143(1) (a) of the Act dated 28.5.1990 for AY 1989-90, rectification order dated 5.2.1991 passed u/s. 154 of the Act rectifying the intimation dated 28.5.1990 and the intimation u/s. 143 (1)(a) of the Act dated 27.3.1991 for the assessment year 1990-91.
(2.) The facts relevant for the present petition are as follows:-
(3.) On 21.12.1989 both the companies had issued TDS certificates to the assessee u/s. 203 of the Act, stating therein that the amount of TDS deducted would be paid to the Central Government within the time permitted by this Court.