(1.) WE are disposing of these two income-tax reference applications under Section 256(1) of the I.T. Act, 1961, by a common judgment as prayed for by Mr. Joshi, learned counsel for the Department. The brief facts giving rise to the references are as follows :
(2.) THE assessment for the year 1959-60 was completed by the ITO on May 8, 1982, on a total income of Rs. 26,597 in which the share of profit of Makhan Singh from the partnership firm of Sriganganagar was determined at Rs. 6,475 and that at Hanumangarh it was determined at Rs. 14,750.
(3.) THE AAC was of the opinion that the decisions cited are not applicable to the present case as action is being taken under Section 147(b) and not under Section 147(a) of the I.T. Act.