1987 (1) TMI 16

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..... 148 of the Income-tax Act, 1961. One notice opened with these words " Whereas I have reason to believe that your income/the income of 1956-57 chargeable to tax for the assessment year in respect of which you are assessable, viz., 1957-58, has escaped assessment within the meaning of section 147 of the Income-tax Act, 1961 ". The other notice opened with the same formula, except that the year firs .....

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..... referred to the year 1957-58, he was referring to the assessment year. Similarly, in the second. There is not the slightest ambiguity in the notices. What is more, the assessee filed returns pursuant to the notices. It did not, apparently, find any ambiguity at that stage. The only question that we are called upon to answer reads thus: " Whether, on the facts and in the circumstances of the ca .....

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