1978 (1) TMI 21

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....etitioner challenges the validity of a notice dated 29th March, 1975, issued under s. 148 of the I.T. Act, 1961, proposing to reopen the assessment of the petitioner-company for the year 1970-71. The principal ground of attack was that the ITO had no reason to believe that any part of the income of the petitioner-company had escaped assessment or that there was any failure in submitting true parti....

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....count. This order was challenged by the assessee in appeal. The AAC held that the counsel for the appellant had submitted that the basa kharch expenses were mainly in respect of employees of the company who were low paid. The learned counsel had, however, not ruled out the possibility that some constituents of the company might also have been entertained from the mess maintained by the company for....

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....sa kharch account in any detail. He only disallowed part of it on the ground that some constituents of the company might have been also entertained. There is no reason to disbelieve when the ITO asserts in his counter-affidavit that while conducting the income-tax proceedings for the subsequent years, the accounts were inivestigated and it was found that the company had inserted in it household....