Summarize the following court judgment. ppeal No. 223 of 1965. Appeal from the judgment and order dated February 23	 1962 of the Madhya Pradesh High Court in Misc. Civil Case No. 165 of 1961. 194 N. A. Palkhivala	 section T. Desai	 T.A. Ramachandran	 J. B. Dadachanji	 for the appellant. A. V. Viswanatha Sastri	 R. H. Dhebar	 N. D. Karkhanis and R. N. Sachthey	 for the respondent. The judgment of the Court was delivered by Subba Rao	 J. This appeal	 on a certificate granted by the Madhya Pradesh High Court	 raises the question whether an appeal lies under section 30(1) of the Indian Income tax Act	 1922	 hereinafter called the Act	 to the Appellate Assistant Commissioner against the order of an Income tax Officer cancelling an order granting registration of a firm under section 26 A of the Act. The facts material for the said question may be briefly stated. The appellant is a firm constituted under a deed of partnership dated July 16	 1948. The Income tax Officer registered the said firm under section 26 A of the Act for the year 1950 51. The registration was renewed for the years 1951 52 and 1952 53. On November 30	 1957	 the Income tax Officer renewed the registration for the assessment year 1953 54. On March 6	 1959	 on the ground that the firm was not a genuine one	 the said officer cancelled the registration under Rule 6 B of the Income tax Rules. The appellant preferred an appeal against that order to the Appellate Assistant Commissioner	 Indore. On July 15	 1959	 the said Assistant Commissioner rejected the appeal for the reason that no appeal lay against the order of the Income tax Officer cancelling the registration. The appeal filed by the appellant against that order to the Income tax Appellate Tribunal	 Bombay	 was dismissed. At the instance of the appellant	 the following question was referred to the High Court under section 66(1) of the Act : "Whether on the facts and circumstances of the case	 the order passed by the Income tax Officer under Rule 6 B of the Indian Income tax Rules cancelling the certificate of renewal of registration granted to the assessee is appealable under section 30 of the Income tax Act. 		 A Division Bench of the High Court of Madhya Pradesh answer ed the reference against the appellant. It held that no appeal lay under section 30 of the Act against the order of the Income tax Officer cancelling registration to the Appellate Assistant Commissioner. Hence the appeal. 195 The only question in this appeal is	 whether an order cancelling the certificate of renewal of registration made under section 26 A of the Act by an Income tax Officer is subject to an appeal under section 30(1) to the Appellate Assistant Commissioner. At the outset	 the relevant provisions may be usefully read Section 26 A. (1) Application may be made to the Income tax Officer on behalf of any firm	 constituted under an instrument of partnership specifying the individual shares of the partners	 for registration for the purposes of this Act and of any other enactment for the time being in force relating to income tax or super tax. (2) The application shall be made by such person or persons	 and at such times and shall contain such particulars and shall be in such form	 and be verified in such manner	 as may be prescribed and it shall be dealt with by the Income tax Officer in such manner as may be prescribed. Rule 6. Any firm to	 whom a certificate of registration has been granted under Rule 4 may apply to the Income tax Officer to have the certificate of registration renewed for a subsequent year Rule 6 A. On receipt of an application under Rule 6 the Income tax Officer may	 if he is satisfied that the application is in order and that there	 is or was a firm in existence constituted as shown in the Instrument of Partnership	 grant to the assessee a certificate signed and dated by him in the following form: Rule 6 B. In the event of the Income tax Officer being satisfied that the certificate granted under Rule 4	 or under Rule 6 A	 has been obtained without there being a genuine firm in existence	 he may cancel the Section 30. (1) Any assessee objecting to the cancellation by an Income tax Officer of the registration of a firm under sub section (4) of section 23 or to a refusal to register a firm under sub section (4) of section 23 or section 26 A may appeal to the Appellate Assistant Commissioner against the assessment or against such refusal or order. " 196 The gist of the said provisions relevant to the present enquiry may be stated thus : Under section 26 A of the Act an application may be made to the Income tax Officer on behalf of a firm for registration for the purposes of the Act. Such an application has to be filed and disposed of in the manner prescribed in the Act. Under the Rules	 an application for the renewal of registration of a firm which has already been registered in the previous years has to be filed before the Income tax Officer. That application will be disposed of in the manner prescribed by Rules 6 A and 6 B. Under those rules	 the Income tax Officer is authorized to make three kinds of orders	 viz.	 (i) he can refuse to renew the registration of the firm; (ii) he can register the firm; and (iii) he can cancel the renewal of registration if he is satisfied that the renewal has been obtained without there being a genuine firm in existence. The crucial point to be noticed is that the said three kinds of orders	 having regard to the circumstances of each case	 will be made only in the application for renewal of registration. The Rules do not provide for independent proceedings for the cancel lation of the renewed certificate. In effect	 the Income tax Officer	 after setting aside his earlier wrong order made under a misapprehension	 refuses renewal of the certificate of registration. If so	 it follows that the order cancelling registration is nothing more than refusing to renew the certificate of registration. If that be the construction of an order made cancelling the certificate re newed	 such an order directly attracts the appellate jurisdiction conferred on the Appellate Assistant Commissioner under section 30 of the Act. But Mr. Viswanatha Sastry for the Revenue contended that there was internal evidence in section 30 of the Act itself to show that such a construction was not possible. He further argued that under the Income tax law there was no scope for equitable considerations	 and under the express provisions of section 30 no appeal Jay against the order of the Income tax Officer cancelling the certificate of registration. In support of his contention he relied upon that part of section 30 of the Act which we have extracted earlier and contended that when the Legislature in the context of the orders made under section 23 (4) spoke separately of the order of can cellation of registration of a firm and an order refusing to register a firm and in the same section	 in the context of section 26 A	 it mentioned only refusal to register a firm	 it clearly expressed its mind that in the former case an appeal would lie against both the orders	 whereas in the latter case an appeal would lie only against one of the orders. There is some force in this argument. But a 197 careful reading of the provisions of section 23 (4) and section 26 A brings out the difference in the phraseology used in section 30 in the matter of appeals against orders made under the said two sections. The relevant parts of section 23 (4) and section 26 A (2) may be placed in juxtaposition : Section 23(4) Section 26 A(2) be. dealt the case of a firm	 may refuse to with by the Income tax Officer in register it or may cancel its registration such manner as may be prescribed. ration if it is already registered. A comparative study of the relevant parts of these two provisions at once shows the distinction between the two. Under section 23(4) while the Income tax Officer can make an order refusing to register a firm or may cancel the registration if it is already registered	 under section 26 A(2) he can only make an order in such manner as may be prescribed. The manner prescribed	 as we have already indicated earlier	 provides for three different kinds of orders to be made in the same application with the result that an order of refusal to renew a certificate and the order cancelling the certificate renewed are given the same effect	 namely	 refusal of the application to register. That apart	 when section 30 provides for an appeal against the orders under section 23(4) and also against orders under section 26 A	 it has incorporated the two forms of orders embodied in section 23(4) and used a general word in providing an appeal against an order under section 26 A	 for the nature of order is not described but left to be prescribed under the Rules. If so	 it follows that the words "refusal to register a firm! ' in section 30 of the Act are wide enough to take in the orders made under rr. 6 A and 6 B refusing to renew the registration and also cancelling the certificate so renewed. By so holding we are not unaware that equity has no place	 in construing the provisions of the Income tax Act. Indeed	 we have not introduced any equitable consideration in the matter of construction. We have come to the conclusion on a fair reading of the relevant provisions of the Act and the Rules made thereunder. In the result	 we answer the question propounded for the High Court 's decision in the affirmative. The order of the High Court is set aside and the appeal is allowed with costs. Appeal allowed.

The Income	 tax Officer cancelled the certificate of renewal of registration of the appellant firm	 under r. 6B of the Income tax Rules	 on the ground that the firm was not a genuine one. The Appellate Assistant Commissioner	 the Tribunal and the High Court on reference	 held that no appeal lay against the order of the Income tax Officer to the Appellate Assistant Commissioner under section 30(1) of the Income tax Act	 1922. In appeal to this Court	 HELD :The words "refusal to register a firm" in section 30 are wide enough to take in the orders made under rr. 6A and 6B refusing to renew registration and also cancelling the certificate so renewed	 and such an order directly attracts the appellate jurisdiction conferred on the Appellate Assistant Commissioner under the section. [196 E; 197 F] The fact that section 30 provides for an appeal separately against the orders under section 23 (4) either refusing to register a firm or cancelling the registration of a firm	 but provides in the context of section 26A	 for an appeal only against an order refusing to register the firm	 does not affect this construction of section 30	 because	 when section 30 provides for an appeal against the orders under section 23(4)	 it has merely incorporated the two forms of orders embodied in section 23(4)	 and	 when it provides for an appeal against the order under section 26A	 it has used a general word	 for the nature of the order under section 26A is not described but is left to be prescribed under the Rules. The application under section 26A made to the Income tax Officer on behalf of a firm for registration for the purposes of the Act	 will be disposed of in the manner prescribed by rr. 6A and 6B. Under these Rules	 the Income tax Officer is authorised to make three kinds of orders	 namely	 (i) he can refuse to renew the registration; (ii) he can register; and (iii) he can cancel the renewal if he is satisfied that a renewal was obtained without there being a genuine firm in existence. But the three kinds of orders	 having regard to the circumstances of each case	 will be made only on an application for renewal of registration	 because	 the Rules do not provide for independent proceedings to the cancellation of the renewed certificate. When the Income tax Officer cancels a renewed certificate	 he sets aside his earlier order and refuses a renewal	 with the result that	 an order of refusal to renew a certificate and the order cancelling the renewed certificate are given the same effect	 namely	 refusal of the application to register. It follows that the order cancelling registration is nothing more than refusing to renew the certificate of registration. [196 A E: 197 C E]