TaxTMI 
TaxTMI 
1982 (6) TMI 132
X X X X Extracts X X X X
X X X X Extracts X X X X
....ry objection of the assessee is that proceedings drawn under section 147 r/w section 148, are invalid, inasmuch as, no reasons, as required by section 147 were recorded by the ITO and as no satisfaction was acquired by the ITO that any income accrued to the assessee and that taxable income had escaped assessment. Shri Mittal, ld. Rep. for the Revenue, placed the entire material before me for perus....
X X X X Extracts X X X X
X X X X Extracts X X X X
....s ' on the report of the Inspector. No reasons, as such, were recorded by the ITO after having received the Inspector's report. The question for consideration is whether, on these facts and circumstances, notice under section 148 r/w section 147, could be issued to the assessee for both the years. From section 148(b), it is amply clear that before issuing the notice, it is imperative for the ITO t....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... and that had escaped assessment. No inference can be drawn from the fact that the assessee had the gross receipts of substantial amount; that there was taxable income of the assessee during the years under appeal and that had escaped assessment. Despite heavy gross receipts, there may be loss or no taxable income. No enquiry was made as to the expenditure of the assessee and as to the net income,....