The fact that s. 30 provides for an appeal separately against the orders under s. 23 ( 4) either refusing to register a firm or cancelling the registration of a firm, but provides in the context of s. 26A, for an appeal only against an order refusing to register the firm, does not affect this con>truction of s. 30, because, when s. 30 provides for an appeal against the orders under s. 23 ( 4), it has merely incorporated the two forms of orders E embodied in s. 23 ( 4), and, when it provides for an appeal against the order under s. 26A, it has used a general word, for the nature of the order under s. 26A is not described but is left to be prescribed under the Rules. The application under s. 26A made to the Income-tax Officer on behalf of a firm for registration for the purposes of th<: Act, will be diaposed 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) F he can cancel the1 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 th·~ 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 eertificate. When the Income-tax Officer cancels a renewed certificate, he sets aside his earlier order and refuses a renewal, with the result G 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 ri~new the certificate of registration. [196 A-E: 197 C-El
