1991 (8) TMI 4 - SC - Income Tax

Reassessment - reasons recorded by the Income-tax Officer on February 26, 1970, which run into more than 20 pages specifically state that the proposed action was under section 147(a) - reasons recorded by the Income-tax Officer justify the issue of the notice under section 147 (a) - assessee's contention that notice was issued under section 147(b) of the Act and not under section 147(a), is not accepted