TMI Blog1986 (9) TMI 44X X X X Extracts X X X X X X X X Extracts X X X X ..... the facts and in the circumstances of the case, the Tribunal was right in holding that the assessee should have filed two appeals, one against the status and quantum under section 246(c) and another against the refusal of registration under section 246(j) and, on that view, in setting aside the order of the Appellate Assistant Commissioner with direction to him to dispose of the appeal afresh, ac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on of Rs. 17,000 in full and reduced the business income from Rs. 18,000 to Rs. 15,000. It was also held by the Appellate Assistant Commissioner that the Income-tax Officer was not justified in treating the appellant as an " association of persons ". The Revenue preferred an appeal before the Income-tax Appellate Tribunal. The Tribunal took the view that two separate appeals, one under clause (c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tration as a firm. The only decision cited on this point supports the contention of the assessee that there is no procedural illegality in filing one composite appeal for obtaining reliefs under the Income-tax Act, 1961, wherein the provisions are different from the Indian Income-tax Act of 1922. The learned counsel for the Revenue does not dispute this position. In CIT v. Rupa Traders [1979] 11 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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