K.N. Seth, J.

1. The assessee is a limited company engaged in the manufacture and sale of sugar machinery. The original assessment for the assessment year 1964-65 was completed on March 29, 1965. The assessment for the assessment year 1965-66 was made on February 24, 1966. For the assessment year 1964-65, reassessment proceeding was initiated under Section 147 of the I.T. Act and completed on December 3, 1968. For the assessment year 1965-66 the Commissioner of Income-tax by his order dated August 23, 1968, passed under Section 264 of the Act allowed a deduction of Rs. 4,800, being income-tax fees paid to M/s. P. L. Tandon and Co. Thereafter, these two assessments were rectified on April 30, 1970, and 17th October, 1968. On 30th December, 1970, the assessee made an application to the ITO under Section 154 claiming relief under Section 80-I on the ground that the assessee manufactured sugar machinery which comes under the head " Priority industry ''. The ITO rejected the claim on the ground that the applications .were barred by limitation provided under Sub-section (7) of Section 154. The AAC rejected the appeals of the assessee on the reasoning that the mistake was committe