K. Ravichandrabaabu, J.

1. The assessee is on appeal as against the order of the Income Tax Appellate Tribunal raising the following substantial questions of law relating to the assessment year 1992-1993 :-

"(1) Whether the Tribunal is correct in confirming the rectification order passed by the respondent for the above assessment year, wherein the provision for gratuity amounting to Rs.4,03,887/- was added back and disallowed in the computation of taxable total income which according to the respondent had been omitted to be disallowed while processing the return under Section 143(1) of the Act and the consquential levy of additional tax ?

(2) Whether the Tribunal is correct in concluding that rectification of the intimation would consequently result in payment of additional tax even though intimation under Section 143(1) of the Act and rectification proceedings under Section 154 of the Act are totally different and distinct procedures envisaged in the Act ?

(3) Whether the Tribunal is correct in law in affirming the rectification order passed under Section 154 of the Act to rectify the intimation issued under Section 143(1)(a) of the Act even though the said proceedings of