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1990 (9) TMI 58

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..... following question for the opinion of this court : "Whether, on the facts and circumstances of the case, the Tribunal was legally justified in holding that the assessment was validly reopened under section 147(b) of the Income-tax Act, 1-961 ?" In this case, an assessment was made on July 25, 1969, for the assessment year 1967-68. Subsequent thereto, it appears that the Inspecting Assistant Co .....

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..... upon the petitioner applied for and obtained the present reference. It is clear from a reading of the order of the Tribunal that the assessment was reopened on the basis of and in pursuance of the report, or remarks, as it may be called, by the Inspecting Assistant Commissioner who pointed out the errors in the assessment order. It is not a case of the Inspecting Assistant Commissioner bringing .....

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