2000 (11) TMI 77

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....onstitution of India, the challenge is to a notice issued under section 148 of the Income-tax Act, 1961, dated March 23, 1989 (annexure J), by the Income-tax Officer to the petitioners for the assessment year 1984-85. The challenge to the notice under section 148 ibid is, inter alia, on the ground that issuing of notice to an association of persons is bad, that it does not record any reasons, t....

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....has supported the issuance of notice under section 148 ibid. The Department has filed copies of the reasons recorded by the Assessing Officer and then the sanction accorded by the Deputy Commissioner (annexure R4) for issuance of notice. None for the petitioner. None for the respondents. Record perused. In my opinion, no ground is made out by the petitioner to successfully assail the impugne....