1999 (8) TMI 23

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.... counsel at some length and also after having perused the records placed before us by learned counsel for the Revenue. We are satisfied that there are no questions of law which require our consideration and which can be said to have arisen out of the order of the Tribunal. Admittedly, the proceeding against the assessee was initiated long after the completion of the year in which the alleged gi....

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....e Deputy Commissioner is satisfied, on the reasons recorded by such Assessing Officer, that it is a fit case for the issue of such notice". The pre-condition for the initiation of proceedings under section 16(1B)(b) of the Act is the satisfaction of the Deputy Commissioner on the reasons recorded by the Assessing Officer that the case is a fit one for the issue of that notice under the provisio....