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1984 (3) TMI 347
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....e judgment of the court was delivered by MEHROTRA J.-We have heard Dr. Misra in support of this petition. The brief facts are these : petitioner No. 1 claims to be a registered partnership firm and it is stated that for the assessment year 1975-76, registration was granted, by the Income-tax Department under s. 185 of the I.T. Act. A true copy of the said order dated September 25, 1982, is anne....
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....ing the validity of the said notice. Dr. Misra has contended that all the necessary facts were in possession of the Department when registration was granted to the assessee-firm on September 25, 1982, and in the instant case, the Department is merely seeking to cancel the registration on change of opinion which it is not entitled to do under s. 186(1). He has placed reliance on a number of auth....
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....s " (vide cl. (a) of section 147). Under cl. (b), the expression is........ the Income-tax Officer has, in consequence of information in his possession, reason to believe ........ The entire case law under the said provision was rendered in reference to the said prerequisites. It is not necessary to notice all the cases which are relevant. However, a reference should be made to the Supreme Cour....