1992 (1) TMI 55

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....sel for the respondent, we dispose of this petition finally. A notice dated September 13, 1991, was served on the petitioner by the respondent under section 148 of the Income-tax Act, 1961. Within one month of the service of the notice, according to a supplementary affidavit, the petitioner filed its return a true copy of which has been annexed to the supplementary affidavit. By a letter dat....

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.... judgment, this court has expressed the opinion that, while it is not open to the assessee to straightaway call upon the Assessing Officer to disclose or indicate the reasons on the basis of which the notice was issued under section 148(1) of the Act, the Assessing Officer is obliged to disclose the reasons once the proceedings assume quasi-judicial character. In the present case, it is not dis....