1996 (3) TMI 33

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....annexure " P-4 "), issued under section 148 read with section 147 of the Income-tax Act, 1961, may be quashed. The brief facts giving rise to this petition are that the petitioner is a registered firm and followed the financial year as the accounting year. The petitioner-firm took certain excise contracts in the auction held in February, 1984, and working of such contracts started from April 1, 1....

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.... confirmation letters with details of cheques and drafts by which the amounts were received, were filed. The Income-tax Officer issued a notice under section 148 of the Income-tax Act on October 11, 1988, proposing to assess and reassess the petitioner-firm for the said assessment year on the ground that the Income-tax Officer had reason to believe that the petitioner's income chargeable to tax fo....

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....ny proceedings available with the Department and they have invited our attention to the proceedings dated January 15, 1991, in which it has been recorded : " As there was no business during the assessment year 1984-85 and no return also filed by the assessee in response to notice under section 148, the proceedings are hereby dropped. Reasons for issuing notice under section 148 are also not recor....

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.... Income-tax Act and now the proceedings are being taken up under this new notice issued on September 10, 1993, we are satisfied that the new notice which has been given has nexus and reasons are given in this notice ; therefore, we are not inclined to interfere with this notice. The original notesheets have been produced before us the reasons and it has been pointed out in the reply filed by the r....