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TMI Blog1978 (12) TMI 92X X X X Extracts X X X X X X X X Extracts X X X X ..... 92-C, 394-C 1976-77 on his file, by which he cancelled the orders passed by the ITO, comp. Cir. II, Coimbatore under s. 144 of the IT Act, 1961 for the asst. years 1968-69, 1969-70 and 1970-71, withdrawing the development rebate which had been allowed in the original assessments made for the above mentioned asst. years. 2. The assessee an individual carrying on the business of manufacture and sa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent rebate and determined the total income as Rs. 1,22,800, 1,41,550 and Rs. 32,820 respectively. 3. Aggrieved by such orders, assessee preferred appeal to the AAC, contending (i) that there was no transfer involved of the machinery in question by reason of the assessee having converted his proprietary business into a partnership business and (ii) that in any event, the order having been passe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... urther provides that such re-computation of the income should be made before the expiry of the period of four years, the period being reckoned from the end of the previous year, in which the sale or transfer took place. In the instant case, the proprietary business of the assessee was converted into a partnership business on 1st May, 69. Assuming that there was a transfer involved in the transacti ..... X X X X Extracts X X X X X X X X Extracts X X X X
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