( 1 ) THIS appeal is directed against the judgment of a learned single judge dated September 2, 1992. The main grievance of the appellant/petitioner in this appeal is that the learned single judge should have quashed the order of the Commissioner of Income-tax dated March 30, 1989, and the order of the Assistant Commissioner dated September 12, 1991, and ought to have held that the amendment in Section 179 of the Income-tax Act, 1961, which was amended in October, 1975, is not applicable in the case of the director of a company who resigned in 1974 when the company has not gone into liquidation. Consequently, the petitioner as well as the petitioner's husband who was one of the directors, before the amendment in Section 179 is not liable for any tax of the company in question under Section 179 of the Income-tax Act, 1961 (hereinafter referred to as "the Act of 1961" ).

( 2 ) THE petitioner's husband expired on May 22, 1988, at Calcutta. The petitioner's husband was one of the directors in Friends United Investors (P.) Ltd. (hereinafter referred to as "the company" ). The husband of the petitioner was the director of the company and resigned from the directorship o