Rakesh Kumar Garg, J.

1. The present appeal has been filed by the Revenue against the order dated May 18, 2007 (annexure A-4), passed by the Income-tax Appellate Tribunal, Amritsar Bench, Amritsar, in I.T.A. No. 2(ASR)/2000 for the assessment year 1995-96 raising the following substantial questions of law:

(i) Whether, on the facts and circumstances of the case, the Appellate Tribunal was right in law in allowing the appeal of the assessee and setting aside the order of the learned Commissioner of Income-tax (Appeals) and quashing the intimation sent by the Assessing Officer under Section 143(1)(a) of the Income-tax Act, 1961?

(ii) Whether, on the facts and circumstances of the case, the learned Income-tax Appellate Tribunal is right in law in taking a view that the changing of status of firm from the trust to an association of persons (AOP) falls outside the purview of Section 143(1)(a) of the Income-tax Act 1961?

2. The brief facts out of which the present appeal has arisen are as under:

The assessee filed income-tax return in this case on March 27, 1997, showing its income as nil. While processing the return under Section 143(1)(a) of the Income-tax Act (for short "the A