1982 (9) TMI 132

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....s to believe that any wealth has escaped assessment and, therefore, the notice given u/s 17(1) (b) was ab initio void. The facts are that the assessee was a partner in the firm M/s Hazarimal Milapchand, on whom the assessment had been made on 29th January, 1977 for the asst. yr. 1975-76. The said firm showed a gross profit rate of 24.46%. Assessment on the assessee was originally made on 18th July....

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....he market value of the closing stock at Rs. 4,72,402 and purportedly had reason to believe that the share of the assessee, i.e., Rs. 1,41,721 in the difference of Rs. 4,72,404, had escaped assessment according to him. On appeal, the AAC relying on his order passed in the case of Mannalal Surana, belonging to the same group, held that no valid reasons were there to reopen the assessment. 2. We h....

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.... the assessment of the firm preceded the original assessment of the assessee, but the correct facts were discovered only after a good deal of research and investigation of the firm's assessment. We asked the revenue time and again to set out the circumstances, which may establish that though the firm's order was available at the stage of the original assessment of the assessee, but some research o....