TMI Blog2018 (3) TMI 1411X X X X Extracts X X X X X X X X Extracts X X X X ..... ndian Government with respect to accounts held in HSBC Bank. Prima facie, such material disclosed that the assessee was an attorney of some account holder. In the Court’s opinion, if the assessee really had no connection with such accounts, no prejudice could really have ensued to him if he would have complied with the notice under Section 142(1) of the Act and filed the consent form. In these cir ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee and the consequent imposition of penalty under Section 271(1)(b) of the Act. It is urged that the findings of the lower authorities are contrary to law. The assessee was served with a notice calling upon him to co-operate and, inter alia, fill a consent-cum-waiver form. The form is set out in the documents annexed to this petition and requires the assessee s consent to enable the tax aut ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nal clause under Section 271(1)(b) of the Act. Learned counsel submits that the action of the Revenue authorities is utterly unwarranted. It is submitted that unless there is some credible material or information requiring the Revenue s further investigations with respect to the assessee s complicity, there was no question of compelling him to answer to the letters and also submit the consent f ..... X X X X Extracts X X X X X X X X Extracts X X X X
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