JUDGMENT

Rajendra Babu, J.-The appellant before us is M/s. Hindustan Aeronautics Ltd., which is a wholly centrally owned Government Company engaged in the manufacture of aeroplanes and its parts. For the assessment year 1970-71, the appellant filed its return before the concerned ITO who by an order made on March 15, 1973 completed the assessment by disallowing certain deductions claimed by the appellant on various grounds. Against the assessment order of the ITO, the assessee filed an appeal before the Appellate Assistant Commissioner who by an order made on October 27, 1976 partly allowed the same. By the order of the Appellate Assistant Commissioner, both the Revenue and the assessee preferred second appeals before the Income Tax Appellate Tribunal, Bangalore to the extent each one of them was aggrieved. However, on May 9, 1977, the assessee withdrew its appeal before the Tribunal with liberty reserved to it to approach the Commissioner of Income Tax (Commissioner) in a revision under Section 264 of the Income Tax Act, 1961 (hereinafter referred to as the Act ). On May 20, 1978, the Tribunal, however, dismissed the appeal filed by the Revenue on merits.

2. The assessee filed revi