1989 (3) TMI 45

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....her, on the facts and in the circumstances of the case and on a correct interpretation of section 146 of the Income-tax Act, 1961, the Tribunal's finding that the assessee had not a reasonable opportunity to comply with or was prevented by sufficient cause from complying with the terms of the notices under section 143(2) and section 142(1) of the Income-tax Act, 1961, was passed on no materials an....

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....ate reasoning has been given as to why this conclusion was reached. The Appellate Assistant Commissioner ultimately ordered that the Income-tax Officer would make a fresh assessment, after communicating to the appellant the particulars of cash credits, viz., dates and amounts of the parties concerned as also the reason why the loans were not considered as genuine loans and how this fact was conce....