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    <title>1974 (9) TMI 21 - PATNA High Court</title>
    <link>https://www.taxtmi.com/caselaws?id=39452</link>
    <description>Reassessment of an escaped association of persons was treated as permissible under the Income-tax Act, 1961 where the materials showed a common income-producing unit and no separate return had been filed in its name. The reopening under section 147(a) was supported by reasonable grounds rather than mere suspicion, and the Commissioner&#039;s sanction was not mechanical because the proposal disclosed the relevant facts. Defective service of the section 148 notice did not vitiate the proceedings where the notice was acted upon and the irregularity was treated as waived. The challenge failed for the later assessment years, but notices for 1960-61 and 1961-62 were invalid because the 1922 Act governed those years.</description>
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    <pubDate>Thu, 12 Sep 1974 00:00:00 +0530</pubDate>
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      <title>1974 (9) TMI 21 - PATNA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=39452</link>
      <description>Reassessment of an escaped association of persons was treated as permissible under the Income-tax Act, 1961 where the materials showed a common income-producing unit and no separate return had been filed in its name. The reopening under section 147(a) was supported by reasonable grounds rather than mere suspicion, and the Commissioner&#039;s sanction was not mechanical because the proposal disclosed the relevant facts. Defective service of the section 148 notice did not vitiate the proceedings where the notice was acted upon and the irregularity was treated as waived. The challenge failed for the later assessment years, but notices for 1960-61 and 1961-62 were invalid because the 1922 Act governed those years.</description>
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      <pubDate>Thu, 12 Sep 1974 00:00:00 +0530</pubDate>
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