1989 (10) TMI 48

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..... following two questions of law for the decision of this court : "(1) Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the reopening of the assessment under section 147(b) of the Income-tax Act, 1961, is not valid and that the opinion or advice of the Law Ministry cannot be considered to constitute information for the purpose of section 147 .....

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..... he decision of the Supreme Court in Indian and Eastern Newspaper Society v. CIT [1979] 119 ITR 996. He also held that the subsidy amount received was only agricultural income and that it cannot be brought to tax under the Income-tax Act. The Appellate Tribunal confirmed the findings of the Commissioner of Income-tax (Appeals) regarding the validity of the reassessment and also the non-exigibility .....

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