C.S.P. Singh, J.

1. THE Income-tax Appellate Tribunal, Delhi Bench, Delhi, has referred the following two questions for our opinion :

"1. Whether the second revised return filed on February 8, 1972, was a valid return under the provisions of Sub-section (5) of Section 139 of the Income-tax Act, 1961 ?

2. IF the answer to question No. 1 is in the affirmative, then whether the time for the completion of assessment was extended up to February 7, 1973, under Section 153(1)(c) of the Income-tax Act, 1961 ? "

The assessee during the previous year relevant to the assessment year 1966-67, was carrying on business in the purchase and sale of motor parts, etc. He filed a return under Section 139(1) showing an income of Rs. 55,489. Thereafter, he filed a revised return under Section 139(5) on the 2nd of March, 1971, showing an income of Rs. 50,273. A second revised return was filed on the 8th of February, 1972, showing an income of Rs. 38,138. The assessment was completed on 6th February, 1973. The assessee appealed, and contended before the AAC that the assessment was time-barred, the contention being that limitation for making the assessment had to be counted from the 2nd of March, 1