1999 (3) TMI 59

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.....-The petitioner is aggrieved by the notices dated March 20, 1997, by which the Income-tax Officer informed him that he had "reason to believe that-income in respect of-assessment years 1994-95 and 1995-96, has escaped assessment within the meaning of section 147 of the Income-tax Act, 1961". These notices related to two years. The reasons were communicated vide documents, copies of which have bee....

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.... by the petitioner into consideration. It is not disputed that the amounts of Rs. 69,538 and Rs. 14,000 have been deposited by the petitioner. According to Mr. Mittal, the deposits had been made on behalf of Mr. Dharam Pal. Is it really so ? Who gave the . money ? What was the source ? These are matters which have to be gone into by the assessing authority. At the present moment, it cannot be s....

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.... the different courts. He has referred to the judgments in R. S. Chiranji Lal and Sons v. CIT [1959] 36 ITR 407 (Punj); Sheo Nath Singh v. AAC of I. T. [1971] 82 ITR 147 (SC) ; Income-tax Officer v. Lakhmani Mewal Das [1976] 103 ITR 437 (SC) and Asoke Kumar Sen v. ITO [1981] 132 ITR 707 (Delhi). It is undoubtedly correct that proceedings under section 147 can be initiated only when the assessing a....