(1.) THIS is a petition by the firm Khushi Ram Raghunath Sahai of Jullundur under Section 66 (3), income-tax Act. The only question involved is whether the petitioner firm's application under section 66 (1) made to the Income-tax Appellate Tribunal at Delhi was rightly rejected as barred by time.
(2.) THE decision of the Appellate Tribunal regarding the petitioner's assessment was delivered on 29-8-1950 and a copy of this decision was received by the petitioner on 28-9-1950. Their application requiring the Appellate Tribunal to refer certain questions of law arising out of the order was posted at Amritsar on 27-11-1950, and arrived in the office of the Appellate Tribunal on 28-11-1950. Section 66 (1) reads: (His Lordship after quoting the provisions stated ). The relevant rules of the Appellate Tribunal are Rules 7 and 36 which are in the following terms:
(3.) I am of the same opinion and there is nothing useful that I am to add.