Narayanan And Co. And K.S. ... vs Commissioner Of Income-Tax on 14 March, 1996
Insofar as the case in question
is concerned, it can be seen that the petitioner
was assessed with the status as a Firm and that
subsequently, following the judgment of this Court
in Narayanan & Company v. Commissioner of Income
Tax (223 ITR 209), assessment was re-opened and the
tax was re-assessed treating the petitioner as an
Association Of Persons. Therefore, situation as
contemplated in paragraph 2 clause (d) was not
available to the petitioner to claim the benefit
thereof.