1991 (8) TMI 31

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....e petitioner and also standing counsel for the Revenue. In the present writ petition, the petitioner has sought for quashing the notice under section 148 of the Income-tax Act, 1961, dated March 18, 1991, and restraining the Assessing Officer, Ward I(4), Kanpur, from proceeding against the petitioner in pursuance of the said notice. The petitioner had already filed an objection to the said noti....

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....ond notice has been issued again under section 148 against the petitioner, which is the subject-matter of challenge in the present writ petition. It cannot be doubted that, if the assessing authority has come to know some facts which led him to believe that some part of the income of the assessee has been left to be assessed, he can always issue another notice under section 148. Only because the e....

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....d and further before confronting the assessee-petitioner with the reasons to believe for issuance of the said notice by supplying him a copy of the same. However, this is without prejudice of the right of the petitioner, if not satisfied with the " reasons to believe ", to challenge the same before the appropriate authority or court, if permissible under the law. The petitioner will file a certifi....