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Issues Involved: Challenge to notices issued u/s 148 of the Income-tax Act for assessment years 1994-95 to 1998-99 based on time-barred claims and lack of jurisdiction.
Judgment Summary: The petitioner challenged notices issued u/s 148 of the Income-tax Act for various assessment years, claiming some notices were time-barred and jurisdiction lacked definite reason to believe income escaped assessment. The Revenue argued that changes in the law required only subjective satisfaction for such proceedings. The court found the writ petition premature, stating the Assessing Officer had the power to reassess income that escaped assessment during proceedings. The court emphasized the wide scope of "in the course of proceedings" and the power to recompute allowances, indicating thorough reassessment. The Explanation to the section highlighted the discretion of the Assessing Officer. The court cited a Supreme Court decision emphasizing the importance of accurate income declarations and the consequences of false statements during assessment. The court concluded that as reliable evidence supported reassessment, the petitioner had the opportunity to address any discrepancies. In conclusion, the court dismissed the original petition, noting the Revenue's assurance not to resort to coercive steps immediately upon reassessment and fresh orders.
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