2009 (4) TMI 131 - BOMBAY HIGH COURT

Issue of notice u/s 147 – Held that - The Assessing Officer had applied his mind and then passed a reasoned order for issuing notice under section 148. There is no dispute on the point that mere issuance of notice would not conclude the issue finally. At that stage, it would be sufficient if the Revenue demonstrates that there were good reasons which were recorded by the Assessing Officer by applying his mind. We find that this court shall not interfere at the stage of mere issuance of notice. The petitioner is not remedyless and all the opportunities which are available to the petitioner in law could be utilized by the assessee – notice issued u/s 147 to be complied with.