2011 (1) TMI 477

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....ENT 1. Heard. 2. Rule. Returnable forthwith. By consent of the parties the petition is taken up for final hearing. 3. The petitioners have challenged the notice dated March 25, 2010 issued under section 148 of the Income-tax Act, 1961. By the said notice the assessment for the assessment year 2004-05 is sought to be reopened by recording the following reasons : "On a perusal of the rec....

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....with 8 and 9 clearly states that the retiring partner discharge the following rights : (i) asset (ii) goodwill (iii) Profit of the partnership business (iv) compensation for loss of right to participate in the profits of the current year in which the partner retires. (v) restricting retiring partner soliciting the clients of the firms for 3 years from the date of retirement attracti....

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....lose fully and truly all material facts necessary for his assessment for this assessment year. The time limit for issuing notice under section 148 of the Income-tax Act is on March 31, 2011. In view of the above, your honour is requested to grant sanction under section 151 for the issue of notice under section 148 of the Income-tax Act 1961." 4. Counsel for the Revenue states that in the case B....