NEW ORISSA TRADERS Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) ON the assessee's application, the Income-tax Appellate Tribunal has stated a case and referred the following question for the opinion of the court :

(2.) ASSESSEE is a partnership firm. For the assessment year 1964-65, the assessee made an application claiming registration of the firm. The accounting period for the relevant assessment year ended on December 31, 1963. The application for registration was filed on 30th of June, 1966--2 1/2 years beyond time in view of the statutory provision that the application has to be filed during the previous accounting year. The Income-tax Officer rejected the application by saying :