1977 (1) TMI 13

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..... ncome-tax Act, 1961 : " 1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that the period of limitation under section 154 of the Income-tax Act, 1961, should be computed from the Order of the Income-tax Officer under section 49A of the Indian Income-tax Act, 1922, dated February 22, 1961, and not from his order dated September 4, 1963, u .....

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..... is order dated February 22, 1961, under section 49A of the Act granting certain reliefs to the assessee under the Agreement for Avoidance of Double Taxation between India and Pakistan. On September 4, 1963, the Income-tax Officer passed an order under section 154 by which he modified the order dated February 22, 1961. In the assessment year 1955-56, the Income-tax Officer passed his order on Mar .....

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..... me to make an application for rectification of the order of the Income-tax Officer should run from his subsequent orders. We are, however, of the opinion that the period of limitation will run from the earlier orders in respect of both the assessment years, and, accordingly, we return our answer in the affirmative and in favour of the revenue. There will be no order as to costs. S. A. MASUD, Act .....

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