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1991 (3) TMI 51

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....tices issued under section 148(1) of the Income-tax Act, 1961, on March 22, 1976, with respect to the assessment years 1967-68 and 1969-70. The assessments for the said two assessment years were made on October 30, 1971, and December 29, 1971, respectively. After receiving the impugned notices, the petitioner says that he filed revised returns on April 21, 1976. Along with the revised returns, the....

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....-68 and 1969-70. The assessee had not repaid that amount. The creditors, after certain years, had written off the said debts as bad and irrecoverable. On that account, the Income-tax Officer wants to treat this amount as income of the assessee under section 41 of the Income-tax Act. So far as the communication of the reasons is concerned, we are of the view that once the assessee filed revised re....

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....ssessee, it is to be communicated to him and he ought to be given an opportunity to rebut the same. This is a requirement of the principle of natural justice. Accordingly, we direct that the Income-tax Officer shall communicate a copy of the reasons recorded by him under section 148(2) of the Income-tax Act to the petitioner forthwith. It shall be open to the petitioner to file such further or fre....