1982 (8) TMI 74

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....eedings under section 147 of the Income-tax Act, 1961 ('the Act'). 2. The assessee is an individual and carries on business in selling empty tins. The assessment year is 1976-77 and the relevant previous year ended on 31-3-1976. 3. Since according to the assessee, he had no taxable income, he did not file his return of income for the year under consideration. On enquiry from the assessee's w....

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....since his total income was Rs. 1,800 only, he was not required to file his return of income and it was not obligatory on his part to show the share of profit of his minor son in the return of income. It was, therefore, urged that the ITO was not justified in initiating the proceedings under section 148/147. The AAC, however, was not impressed by the submissions made on behalf of the assessee, more....

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....en clubbed with the income of the assessee. He, therefore, urged that the assessment framed by the ITO should be cancelled. The learned representative for the department, on the other hand, strongly relied on the orders of the income-tax authorities and justified their action. Relying on a decision of the Hon'ble Supreme Court in the case of CIT v. Smt. P. K. Kochammu Amma [1980] 125 ITR 624, the ....