U.S. DHUSIA, J.M. Revenue is aggrieved by order of CIT (A), Jalandhar, passed in appeal for asst. yr. 1979-80. only issue, that arises in this appeal, is about claim for benefit of registration for assessment year in appeal. ITO had denied benefit of registration and had turned down plea of assessee that he was entitled to renewal of benefit of registration under s. 184(7) of IT Act, but CIT (A) on consideration of facts, vacated order of ITO and directed him to allow benefit of registration to assessee. facts, which have given rise to controversy, are that aforesaid firm of six partners was dissolved on 6th March, 1979. After firm was dissolved, account books were closed on that date. By agreement of dissolution, four partners went out of partnership, leaving assets and liabilities to remaining partners. two partners, after firm had been dissolved, took over assets and liabilities of dissolved firm under new agreement of partnership. It is not necessary for our purpose, but we may note that four partners, who had gone out of partnership, constituted themselves into new partnership. It is in respect of dissolved firm that claim for benefits of registration was made in prescribed Form No.12, necessary declaration had been given in that Form. ITO misunderstood application and considered claim for renewal of registration to be one made for benefits of registration by firm, which, according to him, had undergone reconstitution merely. According to him, it was reconstitution of firm under s. 187 and not of succession under s. 188. He had elaborately discussed his view of matter in order, passed by him under s. 143(3). Accordingly, he found that assessee was liable to file present application in Form No. 11-A for claiming registration for whole of year ended 31st March, 1979. He did not care to notice that assessee had not claimed for grant of registration but only for renewal of registration. Accordingly, he held that assessee was not liable to be allowed order under s. 184(4) which CIT (A) has correctly pointed out, should be taken as order under s. 185(1)(b). Consequently, he disallowed claim for allowing benefit of registration to assessee firm and assessed it as un-registered firm. assessee felt aggrieved and took this matter in appeal before CIT(A). he contended before CIT(A) that ITO had not properly appreciated his claim for allowing him renewal of registration for accounting year from 1st April, 1978 to 6th March, 1979, in respect of old firm which had been dissolved. ITO, on other hand, considered claim of firm as continuing after 6th March, 1979 and he passed order for period 1st April, 1977 to 31st March, 1978. He had erroneously understood that assessee had made claim for grant of registration, when, in fact, he had made claim for renewal of registration for dissolved firm. CIT (A) was moved by plea of assessee and he allowed appeal. Revenue, having felt aggrieved by order of CIT (A), has brought this issue in appeal before us. According to departmental representative, CIT(A) has not made correct finding on facts and has, therefore, cancelled order of ITO. On other hand, ld. counsel for assessee referred to passage from CIT (A) order, where he had recorded clear findings, as under: "The case record shows that assessee had nowhere made claim for registration of firm for assessment year under consideration. application in Form No. 11, together with original copy of Partnership Deed have been placed on file only for asst. yr. 1980-81 and not for assessment year under consideration. assessee has, in fact, filed declaration in Form No. 12, for continuation of registration of firm for asst. yr. 1979-80 and return filed for asst. yr. 1979-80 also discloses profits up to period ending 6th March, 1979, i.e., date of dissolution of firm". "In light of aforesaid facts, it is clear that assessee was entitled to continuation of registration of firm and there was no application in Form No. 11 or 11-A for asst. yr. 1979-80". Having considered rival submissions, we are unable to appreciate plea of Revenue that CIT (A) had committed error in upsetting finding of ITO. CIT (A) had correctly brought out that assessee had applied for renewal of registration and not for grant of registration. He had submitted Form No. 12 and not application in Form No. 11 or 11A. It was because h e had sought renewal of registration for period during which aforesaid firm had continued to be in existence. similar issue had cropped up before this Bench in ITA Nos. 279 & 280 of 1983 in Kejriwal Steel Works, Jalandhar's, case and Tribunal by its order dt. 22nd Nov., 1983, had no hesitation in accepting claim of assessee, dissolved firm, for renewal of registration and in rejecting plea of Revenue that claim of assessee firm was for grant of registration. Following said order and reasons elaborately discussed therein, we uphold finding of CIT (A) and his approach by which he has reached finding to allow renewal of registration to dissolved firm. appeal is dismissed. *** INCOME TAX OFFICER v. BANSAL STEEL INDUSTRIES