JUDGMENT :

J.M. SHELAT, J.

1. Between June 16, 1962, and May 4, 1964, respondent No. 1 was the income tax Officer for Additional B-X VIII District, New Delhi. The appellants have, at all material times, been carrying on business in partnership in the name of M/s. Balwant Singh Santok Singh within the said Additional B-VIII (income tax) District. For the assessment year 1960-61 (accounting year 1959-60), the firm was registered u/s 26A of the income tax Act, 1922. During the assessment proceedings for the assessment year 1961-62 (accounting year 1960-61), respondent No. 1 noticed that the firm had not applied for renewal of registration. The firm was, therefore, liable to be assessed as an unregistered firm. At that stage, appellant No. 1, Balwant Singh, represented to respondent No. 1 that the firm had filed an application for renewal for the assessment year 1961-62 within the prescribed period, and therefore, its registration should be renewed. Respondent No. 1 adjourned the case to May 27, 1963, and called upon appellant No. 1 to produce evidence to show that such an application was made. On May 27, 1963, appellant No. 1 appeared before respondent No. 1 and produced a certificate o