( 1 ) THE assessee is a public limited company. The assessment years relevant to the case are 1960-61 and 1961-62 for which the accounting periods are the financial years ending with the 31st of March 1960 and the 31st of March 1961.

( 2 ) THE returns of income for the respective years were filed on the 16th of January 1961 and the 30th of September, 1961 i. e. to say that these returns were filed prior to the commencement of the Income-tax Act, 1961 hereafter to be referred to as the new Act. The assessments were however made after the commencement of the new Act, namely, on the 8th of November, 1962 and on the 28th of November. 1962 respectively. Both these assessments were made under Section 23 (3) of the Indian Income-tax Act, 1922 hereafter referred to as the old Act.

( 3 ) AS there was a revision under Section 33b of the old Act for the assessment year 1959-60 by the Commissioner of Income-tax, the Income-tax Officer considered it necessary to rectify the assessment orders passed in respect of the later two assessment years viz. 1960-61 and 1961-62 which are now in question. He accordingly issued a notice under Section 154 of the new Act, calling for obj