SABYASACHI MUKHARJI, J.

( 1 ) THIS appeal relates to the assessment for the assessment year 1966-67 under the Income-tax Act, 1961. On the 16th of February, 1967, the original assessment was made under Section 143 (3) of the Income-tax Act, 1961. In the said assessment tax was computed as payable by the petitioner-company on the basis of 25% of the dividend income of Rs. 16,01,769 and the taxable figure arrived at was Rs. 4,00,442'26. After giving the petitioner credit for the tax deducted at source on this account the tax liability of the petitioner was nil on this amount. Thereafter, on the 26th December, 1967, supplementary assessment was made under Section 143 (3) read with Section 147 (a) of the Income-tax Act, 1961, to include the capital gains arising as a result of the sale of 2,14,174 shares of Rs. 10 each to Vazir Sultan Tobacco Co. Ltd. On the 15th of February, 1968, an order was passed under Section 154 of the Act on the ground that there was a mistake in the calculation of tax. In the said order in recomputing the tax, the tax on dividend income was calculated at 25% as was made in the original assessment. Thereafter, on the 5th of January, 1970, another Income-tax Of

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