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1972 (12) TMI 28 - GUJARAT HIGH COURT
When all primary facts were placed before Income-tax Officer at original assessment, whether subsequent change of opinion by the Income-tax Officer permits action under section 34(1)(a) - whether Income-tax Officer getting subsequent information is relevant for action under section 34(1)(a) "(1) Whether, on the facts and in the circumstances of the case, the assessee could validly raise an objection to the issue of notice under section 34(1)(a) ? (2) If the answer to question No. 1 is in the affirmative, whether the facts and the circumstances of the case justified the issue of notice under section 34(1)(a) ?" - Q. (1): Not pressed on behalf of the revenue. Therefore, answered in the affirmative. Q. (2): In the negative.