Tribunal held that  for the assessment years 1981-82 to 1984-85 the books of account of the assessee were prepared on calendar year basis with the year ending on December 31. From the assessment year 1985-86 onwards the assessee had changed its method of presentation of annual accounts and opted for the financial year ending 31st March, as the cut-off date. Section 3 of the Act, gave an option to the assessee to select a previous year different from the financial year provided its annual accounts were drawn up in line with the option selected by the assessee. Therefore, the previous year of the assessee should be taken as the period starting from January 1, 1983 to December 31, 1983 and the effective date of the settlement agreement was January 1, 1984. The assessee’s previous year would end on December 31, 1984 and hence, the receipt if at all had to be taxed in the assessment year 1985-86 and not 1984-85. The additional ground was allowed and the issues were restored to the file of the Assessing Officer to be decided afresh. (AY. 1984-85)