1989 (6) TMI 20

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..... The assessment of the petitioners for that assessment year was completed on September 19, 1981. The appeal filed therefrom was decided on December 7, 1981. Notice purporting to reopen the assessment under section 147(b) of the Income-tax Act, 1961, was issued to the petitioners on October 11, 1982. The petitioners' chartered accountants sought the reasons for the initiation of these reassessment p .....

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..... d on a scrap of paper the origin and correctness of which he cannot vouch for. There is no basis upon which the court can conclude that the conditions set out in clause (b) of section 147 of the Act have been complied with. The notice dated October 11, 1982, issued under those provisions must, therefore, be quashed. Rule made absolute accordingly. The respondents shall pay to the petitioners th .....

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