TaxTMI 
TaxTMI 
1962 (2) TMI 72
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....s been a real opportunity given to the petitioner to place his objections to the pre-assessment notice. Even the pre-assessment notice that has been furnished to the petitioner, viz., exhibit P-1, except attempting to comply with an empty formality, as such, does not at all give any indication as to what basis the assessing authority proposes to adopt. 2.. No doubt, in the pre-assessment notice, ....
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.... far as this is concerned, the petitioner has categorically stated that this notice, which gives him time to furnish his explanation till 30th July, 1960, was admittedly received by him only on 1st August, 1960, and that fact has also been admitted by the respondent. 5.. But, according to the respondent, the petitioner appeared before the assessing authority on 4th August, 1960, and gave a statem....
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....ion to the endorsement on the application to the effect that the assessing authority has made a note that the petitioner was asked as to whether fresh notice is to be served on him, and the petitioner said that it is not necessary to issue him a fresh pre-assessment notice and that the assessment as against him may be made. 8.. This controversy clearly shows that the petitioner must be given an o....
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....over can very fairly be estimated 10 to 12 times the average stock handled. 11.. These aspects, according to the learned counsel, have not at all been indicated in exhibit P-1, and therefore, the pre-assessment notice exhibit P-1 does not serve any purpose whatsoever so far as the petitioner is concerned. There seems to be considerable force in this criticism levelled against the pre-assessment n....