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2010 (11) TMI 739 - HC - Income TaxNotice - notice has been issued without there being any reasons for proceeding under section 147 of the Act. In the circumstances, we find ourselves in disagreement with the submissions made by the learned counsel for the petitioner that there is no basis or no sufficient reason exist for the respondent to have issued notice to the petitioner. On the other hand, on going through the reasons recorded by the respondent we find that there is a finding recorded about existence of reason to believe. In our view no illegality much less jurisdictional error has been committed by the respondent in issuing notice to the petitioner so as to invoke our jurisdiction under Article 226 of the Constitution of India, the petitioner is free to raise the grounds about the merits of the matter in the proceedings under section 147 of the Act, the petition fails and is hereby dismissed
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