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TMI Blog2014 (2) TMI 1120X X X X Extracts X X X X X X X X Extracts X X X X ..... ion 154 holding that no mistake was apparent from records – Held that:- The decision in COMMISSIONER OF INCOME-TAX Versus KD. PRABHAKAR (HUF) [2007 (8) TMI 335 - PUNJAB AND HARYANA HIGH COURT] followed – the amendment was applicable from 1985-86 and subsequent years – thus, the interest for the assessment year 1981-82 is not valid – Decided against Revenue. - ITR No. 3 of 2002 - - - Dated:- 3-2- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5/217 was concerned, for the assessment year 1981-82? 2. Briefly, the facts relevant for the decision of the controversy involved, as available on the record, may be noticed. Assessment was originally completed at total income of Rs. 20,080/- plus agricultural income of Rs. 700/-. Subsequently, in the course of assessment proceedings for the assessment year 1990-91, it came to the notice of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... decision of the Apex Court in Rama Bai and others vs. Commissioner of Income Tax, (1990) 181 ITR 400 but the assessee did so only for and from the assessment years 1984-85 onwards. Therefore, proceedings under section 147 of the Act were initiated and notices under section 148 were issued to the assessee by post on 31.1.1992 for the assessment years 1974-75 to 1983-84. The assessee filed return d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r dated 30.9.1996 dismissed the same. Still not satisfied with the order, the assessee filed appeal before the Tribunal. Vide order dated 26.11.1997, the Tribunal allowed the appeal while setting aside the order of the DCIT(A) and restoring the matter back to the Assessing officer to decide the application under section 154 of the Act afresh. Hence the present reference at the instance of the reve ..... X X X X Extracts X X X X X X X X Extracts X X X X
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