Gokal Chand Mital, J.

1. The main point involved in this reference is whether the limitation of eight years contained in Section 153(1)(b) of the Income-tax Act, 1961 (for short "the Act"), would be applicable. The case relates to the assessment year 1972-73.

2. On September 26, 1974, the premises of the assessee were searched and documents, registers and account books were taken into possession. The deduction of salary paid to its workers as shown in the attendance/ wages register was claimed in the return by way of expenses for running the business.

3. The Income-tax Officer doubted the genuineness of the revenue stamps in the register and sent them to the Government Printing Press, Nasik, and on March 4, 1975, a report was received that the revenue stamps fixed on the said register were printed on May 8, 1972, and issued on May 22, 1972. On the basis of this report, the Income-tax Officer formed a tentative opinion that the revenue stamps were not in existence in the financial year 1971-72. The register was fabricated and a false claim for deduction was made in the return. He brought this fact to the notice of the assessee by letters dated January 7, 1975, January 10, 19