( 1 ) THIS appeal by the Revenue impugns the judgment of the High Court quashing the orders dated 30-1-1978 and 8-3-1983 made respectively by the inspecting Assistant Commissioner of Income Tax and the Income Tax appellate Tribunal, and directing refund of a sum of Rs 32,85,964 to the respondent assessee.

( 2 ) THE assessee was issued notices by the Income Tax Officer under section 11 of the Business Profits Tax Act, 1947 (for short "the Act") and called upon to "furnish returns thereunder in respect of the chargeable accounting periods ending on 31-12-1946, 31-12-1947, 31-12-1948 and 31-3-1949. Such returns were filed by the assessee on 31-3-1949 and provisional assessments under Section 13 of the Act were completed on different dates between 27-12-1948 to 22-1-1951 by the Assessing Officer. On 30-12-1969, the regular assessments under Section 12 of the Act were completed in respect of the aforesaid three chargeable accounting periods. The respondent assessee filed appeals before the Income Tax Appellate tribunal (for short "the Tribunal") impugning the regular assessment orders on various grounds including the ground that the regular assessment orders were barred by time. The Tri