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The High Court of Allahabad ruled that the appellate authority had the power to direct the Income-tax Officer to make two separate assessments for different periods. The judgment was delivered by B.P. Jeevan Reddy C.J. and R.A. Sharma. The court found that sub-section (3) of section 153 of the Income-tax Act allows for such situations where a fresh assessment is made or in consequence of an appellate order. The reference was answered in favor of the Revenue and against the assessee.
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