TaxTMI 
TaxTMI 
2003 (2) TMI 458
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....ation is, whether reassessment notice issued for the period 1994-95 (April 1, 1994 to March 31, 1995) is legal or not?. 3. It is not in dispute that the assessment for the year in question was completed on June 30, 1998 (annexure P 7) and later after remand by the Appellate court, it was completed on June 27, 2001 (annexure P 14). The reason for reopening of the assessment was also conveyed to petitioner alongwith the impugned notice. It is worth to quote in verbatim in Hindi: 4. In my opinion, aforesaid reasons are not only material and decisive but fully empowers the assessing authority to reopen the assessment. Indeed, it is a case where the petitioner filed certain documents (builty, invoices etc.) of transport companies in assessmen....
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.... is a forged/bogus one, the assessment order based on such document can never be allowed to sustain. It has to go. 6.. The assessing officer has given full and complete details of an inquiry conducted in relation to such documents. They are quoted in the reasons. They are equally communicated to the petitioner. It, thus, satisfies the requirement of statute dealing with the cases of reassessment. It is now for the assessing officer, to make reassessment after granting adequate opportunity to the petitioner. 7.. Submission of learned counsel for the petitioner was that no notice under the repealed Act could be issued. I do not agree. It is a submission more in the nature of technical than that of substance. It cannot be disputed that the ....