TaxTMI 
TaxTMI 
2006 (7) TMI 172
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....tt, learned counsel for the Revenue, are heard. At the instance of the assessee, the Tribunal has referred the following questions to this court for our opinion: "1. Whether, on facts and in law, the Tribunal was justified in upholding the action under section 147(a) of the Income-tax Act, 1961? 2. Whether, on facts and in law, the Tribunal was right in treating the said cash credits as not gen....
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....ts of the said case, we must immediately say that the facts of the said case were totally different. In the present case, the Assessing Officer when making a fact finding inquiry, examined some of the creditors and after a thorough cross-examination, he was successful in obtaining the information from the witness that the witness, in fact, had no money with him, he was having certain agricultural ....
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....transaction, call for any interference. So far as the first question is concerned, learned counsel for the assessee submitted that before issuing a notice under section. 147(a) of the Income-tax Act, the Assessing Officer must be sure of the grounds available to him and he cannot be allowed to make a fishing inquiry. His submission is that simultaneous issue of notice to the firm, so also to the ....