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Issues involved:
Challenge to reassessment notices for assessment years 1989-90 to 1993-94 by a stock exchange claiming exemption under various sections of the Income-tax Act. Judgment Details: - Issue 1: Exemption under section 11 and 10(23C)(iv) The petitioner claimed exemption under section 11 and later under section 10(23C)(iv) but faced challenges in renewal. After a series of communications and orders, a fresh application was permitted for relevant assessment years. The Central Government ultimately communicated its decision denying notification under section 10(23C)(iv) due to the stock exchange's activities primarily benefiting its members. - Issue 2: Validity of Reassessment Notices For assessment years 1989-90 to 1993-94, the Assessing Officer issued reassessment notices based on reasons specific to each year. The petitioner challenged the validity of these notices, alleging errors in reasons recorded and mechanical sanction by the Deputy Commissioner. The court held that the reasons provided were cogent and valid, satisfying the requirements under section 148 of the Act. - Issue 3: Compliance with Section 151(2) Regarding the requirement of sanction under section 151 of the Act for reassessment beyond four years, the court found that the Deputy Commissioner had applied his mind to the reasons recorded by the Assessing Officer, dismissing the petitioner's contention of mechanical approval. - Issue 4: Sufficiency of Reasons for Reassessment The court emphasized that the reasons given in the reassessment notices had a direct and rational connection with the formation of the Assessing Officer's belief under section 148. Citing legal precedents, the court concluded that the reasons provided were valid and in compliance with the law. In conclusion, the court rejected the petition challenging the reassessment notices, stating that they were lawfully issued and there was no basis for interference. The interim relief was vacated, and no costs were awarded.
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