NARANJAN SINGH Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) BENCH , Amritsar (for short, 'the Tribunal'), in ITA Nos. 531 to 534/Asr/1998, for the asst. yrs. 1992 -93 to 1995 -96.

(2.) AT the time of admission of appeals, the following substantial question of law was framed for adjudication by this Court :

(3.) FIRSTLY , the case for the asst. yr. 1992 -93 is being taken up. Return for the year in question was filed by the assessee as, by that time, dispute regarding carry forward of losses for the year 1991 -92 had not been settled in appeal. It was depreciation of Rs. 4,57,629 was quantified to be carried forward to the next year. Even before the appeal effect was application under s. 154 of the IT Act, 1961 (for short, 'the Act') for rectification of the orders passed for the asst. yr. 1992 -93 for the giving consequential effect in the year of the appeal effect order passed for the asst. yr. 1992 -93. The processed under s. 143(1)(a) of the Act, no action under s. 154 of the Act is possible. In appeal, the assessee succeeded before the Commissioner of Income -tax (Appeals) [for short, 'the CIT(A)'], but in further appeal by the Revenue, the Tribunal reversed the order of the CIT(A).