1962 (2) TMI 72

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....sing authority proposes to adopt. 2.. No doubt, in the pre-assessment notice, exhibit P-1 dated 23rd July, 1960, there are certain defects pointed out, which, according to the officer, exist in the books of account that have been produced. After mentioning some of these aspects, ultimately the assessing authority states that the accounts have been rejected in the previous years, and it is, therefore, proposed to reject the book results and estimate the turnover to the best of his judgment. 3.. But, having mentioned it, there is absolutely no further indication in the notice exhibit P-1 as to what is the basis on which he proposes to make an estimate according to the best of his judgment. The notice finally winds up by calling upon the....

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....s 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 opportunity again to place his objections to a proper notice that may be issued by the assessing authority, in the light of the directions contained herein. 9.. Mr. V. Rama Shenoi, learned counsel for the petitioner urged that the pre-assessment notice exhibit P-1 does not at all give any indication of the basis or the method or the data on the basis of which the officer proposes to make the assessment on best judgment basis. 10.. In this connection, the learned counsel referred me to the assessme....