Satish Chandra, C.J.

1. THE assessee is a registered firm constituted under an instrument of partnership of April 8, 1960. It consisted of five partners. Two minors were admitted to the benefits of the partnership.

2. FOR the assessment year 1961-62 the firm was granted registration. It was renewed from year to year up to 1969-70. FOR the year 1968-69 the assessment order was passed on 8th July, 1969, and for the assessment year 1969-70 on 4th December, 1969. In the body of these assessment orders the ITO granted renewal of registration to the assessee-firm.

The CIT found that Chandi Prasad, one of the minors, had attained majority on 4th January, 1964, and thereafter he had been made a full-fledged partner in the firm. He felt that there has been a change in the constitution of the firm, and since no fresh partnership deed was drawn up, the renewal of registration with effect from 1965-66 onwards was erroneous and prejudicial to the interests of the revenue. Since assessment years 1965-66 to 1967-68 were beyond the prescribed period of limitation for action under Section 263(1) of the I.T. Act, he issued notices for the assessment years 1968-69 and 1969-70, After hearing t