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The High Court of Delhi addressed the validity of notices under section 147(a) read with section 148 of the Income-tax Act, 1961. The court directed the Income-tax Officer to decide on the connection between alleged concealment of income and the material presented before proceeding with the assessment reopening. If no connection is found, the proceedings must be dropped. The petitioner can challenge this decision before the Appellate Assistant Commissioner, the Tribunal, and potentially the High Court.
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