1995 (7) TMI 46

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....es service of rule for the respondent. By this petition, the petitioner challenges the notice, exhibit-K dated February 7, 1994, issued under section 148 read with section 147 of the Income-tax Act, 1961, inter alia, on the ground that, on the face of it, the assessee has not been found to have failed to disclose truly and fully all material facts necessary for the assessment of its income duri....

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....ssing Officer a duty to record his reasons for holding such a belief before issuing notice under section 148. On the assessee's demand in the present case, reasons for initiating proceedings for reassessment were disclosed by communication dated January 3, 1995, vide exhibit-L. Having perused the reasons we find that there is no whisper about the satisfaction of the assessing authority, much....