Court : Supreme Court of India
Reported in : [1966]3SCR359
Bachawat, J. 1. The appeal raises a question of interpretation of the proviso to clause (i)(a) of s. 2(11) of the Indian Income-tax Act, 1922. Up to the assessment year 1951-52, the appellant adopted the year ending on June 30 as the 'previous year' applicable to him. The assessment for the assessment year, 1951-52 was accordingly made in respect of the previous year ended on June 30, 1950. For the assessment year, 1952-53, the assessee field a return for 21 months commencing on July 1, 1950 and ending on March 31, 1952, and requested the Income-tax Officer to accord his sanction to the change of the previous year from an year ending on June 30 to an year ending on March 31. The Income-tax Officer duly sectioned the change. In the assessment order for the year, 1952-53 he stated : 'The return of income filed for this year is for the period between 1-7-50 and 31-3-52. The permission to change the previous year is granted subject to the condition that the total income in the period of 21...
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