1995 (4) TMI 55

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... --This petition is directed against the initiation of the proceedings under section 147 of the Income-tax Act, 1961, by issuing notices under section 148 of the Income-tax Act, 1961 ("the Act", for short). For reopening the assessment of the assessment years 1980-81 to 1985-86, notices were issued on March 28, 1989. In response to the objections raised by the assessee and requiring the Income-tax....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....assessment years 1980-81 to 1985-86, because it is presumed, on the basis of incorrect and incomplete information supplied by you to that effect, that the buildings under consideration were being used by you for your own business. I had reason to believe that, due to failure on your part to disclose fully and truly all material facts in respect of the correct use of house properties owned by yo....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....oceedings for the assessment year 1986-87 that the buildings in question were rented out and that no business had been carried on. No return has been filed. However, the Revenue has supported the order in question on the basis of the reasons disclosed by the concerned authority in his letter dated April 11, 1989, annexed to the petition. Learned counsel appearing for the assessee has contend....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ome from licensing of trade mark "Ranjit" and letting out of the factory premises for business. Even in the order, it is noticed that the nature of the business of the assessee-firm is to exploit the trade mark and other related marks by assigning and/or licensing the same, permitting others to use the same on the stipulated terms and conditions and to let out a portion of the factory buildings fo....