1999 (2) TMI 20

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....f notices under section 148 of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), for the assessment years 1989-90, 1990-91, 1991-92 and 1992-93, respectively. The original assessments for all the years were duly completed under section 143(3) of the Act in which the assessee had shown substantial amounts of income as agricultural income from land taken on lease. In addition, the ass....

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....en and, therefore, the notices are barred by time. We have heard Sri Vikram Gulati, learned counsel for the petitioner, and Sri A. N. Mahajan, learned standing counsel for the respondent. Reliance is placed on a judgment of the Patna High Court in Dhanaraj Singh and Co. v. CIT [1996] 218 ITR 312, in which it was held that where loans were received by account payee cheques and have been accep....

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....had treated the loans as genuine. Subsequent fresh information specific in nature and reliable in character relating to the concluded assessment which goes to expose the falsity of the loan and the statement made by the assessee at the time of the original assessment is different from drawing I fresh inference. The Supreme Court held that on such facts the Income-tax Officer had jurisdiction to re....