TaxTMI 
TaxTMI 
2008 (2) TMI 309
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....ies. In the case of these customers, large quantities of steel was involved and these customers used to provide Essentiality Certificates to enable the petitioners to procure steel from the Steel Authority of India Ltd., This certificate enables the petitioners easily to procure the requisite quantity of steel at lower or concessional rates. The certificates issued are based on requirement of steel on the basis of drawings and designs submitted by the petitioners to the customers. The quotations to these parties include a change for steel at the controlled/concessional rates. The petitioners placed orders on its vendors for supply of steel equipment. As the petitioners did not have any manufacturing or storage facilities and did not have th....
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.... purchase from SAIL. Respondent no.1 after careful scrutiny, by order dated 20.3.1985 completed petitioners' assessment under Section 143(3) of the Act for the assessment year 1982-83. Aggrieved by the order, the petitioners preferred an appeal. 3. Notice under Section 148 was served on the petitioners on or about 30.3.1990 stating therein that they had reason to believe that the petitioners' income chargeable to tax for the assessment year 1982-83 had escaped assessment within the meaning of Section 147 of the Act and that they proposed to re-assess the petitioners' income for that assessment year. The petitioners filed their return and subsequently this petition to challenge the said notice. It is the case of the petitioners that i....
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....al based on which the notice under Section 147 was issued and the material based upon which the officer come to the conclusion that he has reasons to believe. 6. An additional affidavit was filed by one Anu Krishna, to which some documents including the statement recorded of one J. M. Sanghvi has been annexed. From the statement of J. M. Sanghvi it has come on record that he was instrumental in helping one Girish Joshi and his brother Pravin A. Joshi and Jayesh A. Joshi in setting up two bogus firms for the purpose of selling steel from various parties. The statements of the Joshi brothers were not placed. The two bogus concerns were M/s. J. Sanghvi & Co. and M/s. Lilly Enterprises. At today's hearing the matter was posted for orders today....