Judgment

Bharucha, J.-The basic questions with which we are concerned in these appeals, relating to the Assessment Year 1976-77, read thus :

“(i) Whether on the facts and in the circumstances of the case, was the Tribunal right in holding that the Commissioner of Income Tax had jurisdiction u/s 263 of the Income Tax Act to revise the order of the Income Tax Officer passed after obtaining directions from the Inspecting Assistant Commissioner under Section 144B of the Act?

(ii) Whether on the facts and in the circumstances of the case, was the Appellate Tribunal right in law in holding that assessment year 1975-76 is the 8th assessment year immediately succeeding the assessment year 1967-68 for the purpose of carry forward and set off of unabsorbed development rebate under Section 33(2)(ii) of the Act and not the assessment year 1976-77?

(iii) Whether on the facts and in the circumstances of the case the Appellate Tribunal right in holding that for the purpose of carry forward of 80J relief the assessment year 1975-76 is the 4th assessment year immediately succeeding the assessment year 1971-72 and not the assessment year 1976-77?