2001 (7) TMI 55

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....01, annexure 4 to the writ petition, issued under section 148 of the Income-tax Act, 1961. The notice is in the context of incomes of a Hindu undivided family on which the assessee was assessable to tax for the assessment year 1993-94. It needs to be mentioned that earlier to this notice of March 30, 2001, under section 148 (indicated to the court as having been received on the date as in the n....

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....d this is accepted. Perhaps, if the assessee had responded to the notice of March 1, 2001, then, the subsequent stage may not have arrived. On this aspect there is nothing on the record of the petition. In so far as the notice under section 148 is concerned, the issue is not that no reason has been recorded as it is accepted that reasons are on record and the notice was issued subsequently. ....

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....ce on the writ petition and for quashing the notice under section 148 of the Act. A careful reading of this case shows that the context has been torn out on submissions as made. This case explains that the Commissioner should be satisfied on the reasons recorded by the Income-tax Officer that it is a fit case for issue of such notice. It is in this very case that the Supreme Court has observed upo....