1980 (6) TMI 1

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....ality of the notice issued under s. 148 of the I.T. Act, 1961, proposing to take action under s. 147 of the Act in respect of the assessment for the year 1968-69. For the assessment year 1968-69, assessment was completed on March 22, 1972, (Ex. A) on July 24, 1975, notice was issued under s. 148 of the Act on the ground that the ITO had reason to believe that certain income exigible to tax duri....

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....ed the expenditure incurred towards the commencement of the business even prior to the said date. This point for the petitioner is covered in his favour by the decision of the Supreme Court in Gemini Leather Stores v. ITO [1975] 100 ITR 1. Further in the case of C. T. Desai v. CIT [1979] 120 ITR 240, this court has held that business expenditure incurred prior to the commencement of the busines....