1973 (3) TMI 15

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....s a partnership firm registered under the Indian Partnership Act. The petitioner is also registered under the provisions of the Income-tax Act. The partners of the petitioner are Biswanath Samanta, Tarapada Daw and Prasanta Samanta. For the assessment year 1960-61 the Income-tax Officer, A-Ward, Special Survey Circle II, Calcutta, completed the assessment of the petitioner under section 23(3)/23(5)(a) of the Indian Income-tax Act, 1922. The petitioner, it is stated, at the time of the said assessment furnished to the assessing Income-tax Officer all challans and particulars relating to all primary and relevant facts that were necessary to be ascertained for the purpose of assessing the income of the petitioner for the said assessment year. ....

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....,000 11. Teekamdas Madhabdas do. 15,000 ---------------- 2,25,000 ----------------- Thus it is seen that at the time of the original assessment, the assessee failed to disclose its income from other sources representing unaccounted money introduced in the shape of bogus loans." In short, the deponent in the aforesaid affidavit has disclosed the following reasons for the issue of the said notice under section 148 of the new Act : (1) At the time of the original assessment the assessee's hundi loan transactions with various parties were accepted as genuine without detailed enquiry ; (2) During the course of subsequent years' assessment proceedings it was found on investigation that the assessee's hundi loan transaction....