TMI Blog2001 (7) TMI 55X X X X Extracts X X X X X X X X Extracts X X X X ..... . The notice is in the context of incomes of a Hindu undivided family on which the assessee was assessable to tax for the assessment year 1993-94. It needs to be mentioned that earlier to this notice of March 30, 2001, under section 148 (indicated to the court as having been received on the date as in the notice), another notice No. 5692, dated March 1, 2001 (annexure 3), was also received by t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 01, then, the subsequent stage may not have arrived. On this aspect there is nothing on the record of the petition. In so far as the notice under section 148 is concerned, the issue is not that no reason has been recorded as it is accepted that reasons are on record and the notice was issued subsequently. The first submission which was made on behalf of the assessee is that the Income-tax Office ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reading of this case shows that the context has been torn out on submissions as made. This case explains that the Commissioner should be satisfied on the reasons recorded by the Income-tax Officer that it is a fit case for issue of such notice. It is in this very case that the Supreme Court has observed upon the duty which is cast upon an assessee to make a true and full disclosure of the primary ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
