( 1 ) THE appellant, M/s. Jiyajeerao Cotton Mills Ltd. , a public company, derived profits and gains from several industries owned by it, one of which was a chemical factory known as Saurashtra Chemicals, situate at Porbander, where during the previous year relevant to the assessment year 1966-67, soda ash was manufactured.

( 2 ) THERE is no dispute that soda ash is one of the items mentioned in Part III of the First Schedule to the Finance Act, 1965, and the appellant was, therefore, entitled to a special rebate of 35 per cent. on the profits and gains attributable to the business of manufacture and production of soda ash under Paragraph F of Part I of the First Schedule to the Finance Act, 1965.

( 3 ) THE appellant had at first filed its income-tax return for the assessment year 1966-67, without claiming the said special rebate under Paragraph F of Part I of the First Schedule to the Finance Act, 1965, in respect of its profits and gains attributable to the business of manufacture and production of soda ash in Saurashtra Chemicals but subsequently filed a revised return claiming such rebate.

( 4 ) ON or about the 27th February, 1970, respondent No. 1 complet