1989 (5) TMI 83

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....s contested. 2. The assessee, as in the past, filed his return on 17-8-1982 on estimate basis declaring an income of Rs. 9,000 in compliance to notice under section 139(2) of the Act. The ITO on 21-4-1983 issued a letter stating that the returns for the assessment years 1981-82 and 1982-83 were defective in the context of section 139(9)(f) of the Act. Since in respect of assessment year 1982-83 the charge that the assessee failed to comply with the statutory obligation of the said section came to be dropped it is considered necessary to notice in the order the said letter of the ITO as follows :-- " To Shree Gurdial Singh, S/o. Shri Mohinder Singh, Truck Owner, Village & Post Office Dakoha, Tehsil and Distt. Jalandhar. ....

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.... the assessment years 1981-82 and 1982-83 stating that the returns for both the assessment years would be considered invalid as there were non-compliance and violation of clause (f) of section 139(9) of the Act. Another communication dated 16/18-6-1983 was also issued. Still another letter of the ITO dated 29-7-1983 in respect of assessment year 1981-82 also required the assessee to comply with requirement of clause (f) of section 139(9). The assessee, however, stated that he had no information and, therefore, was unable to furnish details as required. 4. Thereupon the ITO framed the assessment on estimate basis keeping in focus the earlier pattern of assessment and estimated the income from as many as five trucks, which were the same as....