1979 (1) TMI 2 - SC - Income Tax

Interest paid by the respondent to creditors from whom it claimed to have borrowed monies on hundis - ITO merely stated his belief but did not set out any material on the basis of which he had arrived at such belief so that the court could decide for itself whether there was any material on the basis of which the ITO could reasonably entertain such belief - notice under s. 147(a) of the I.T. Act for reopening the assessment must in the circumstances be held to be void.