SABYASACHI MUKHARJI, J.

( 1 ) I am concerned in this application with the validity of the notice under Section 154 of the Income-tax Act, 1961, issued on 15th November, 1971. The notice relates to the assessment year 1963-64, the relevant accounting year for which ended on 31st March, 1963, The petitioner was assessed under Section 143 (3) of the Income-tax Act, 1961, in which the petitioner's total income was computed at Rs. 96,03,460. The petitioner is a public limited company and carries on business, inter alia, of manufacturing textile goods and chemical products. During the period relevant for the assessment year 1960-61, the petitioner had set up a new unit for manufacturing, inter alia, soda ash, caustic soda and other chemicals at Porbandar in Saurashtra. In the order of assessment for the assessment year 1963-64, the Income-tax Officer had allowed to the petitioner relief under Section 84 of the Income-tax Act, 1961, as it stood in the relevant year in respect of the said chemical unit set up at Porbandar, The relief was allowed under Section 84 of the Act by the said order and was to the extent of Rs. 8,72,753. Being aggrieved by certain disallowances, the assessee prefe

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