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Issues:
1. Validity of assessment under s. 144 read with s. 147(a). 2. Compliance with notice requirements under s. 148(1). 3. Dispute over issuance and service of notices under s. 148 for different assessment years. 4. Bar on assessment due to time limitation under s. 153(2)(a). 5. Need for proper verification and reconsideration of assessment by the Assessing Officer. Analysis: 1. The assessment in question was made under s. 144 read with s. 147(a) for the assessment year 1981-82 due to non-filing of the return by the assessee. The assessment was primarily based on incriminating documents found during a search, leading to the determination of the business income. The assessee contested the assessment's validity, arguing that proper deductions were not considered, and the assessment was ex parte. 2. The validity of the assessment under s. 147(a) was challenged by the assessee on the grounds of non-compliance with notice requirements under s. 148(1). The Assessing Officer was alleged to have not recorded reasons for initiating the assessment, as mandated by s. 148(2). Despite discrepancies in the record, including missing notings, affidavits were submitted to support the issuance and service of notices under s. 148. 3. Disputes arose regarding the issuance and service of notices under s. 148 for different assessment years, specifically for 1981-82 and 1980-81. The assessee claimed that earlier notices were issued and served, while the Revenue presented conflicting evidence regarding the timing and content of the notices. The discrepancies raised questions about the timeline and legality of the assessment under consideration. 4. The assessee contended that the assessment was time-barred under s. 153(2)(a) due to the alleged issuance of earlier notices, which should have initiated the assessment process. The timing of notices and their relation to the assessment year in question became crucial in determining the applicability of the time limitation provision. 5. In light of the discrepancies and unresolved issues related to notice issuance, service, and compliance, the Appellate Tribunal decided to set aside the assessment and remand the matter to the Assessing Officer for thorough verification. The Tribunal directed the reassessment process, emphasizing the need for proper consideration of all relevant facts, including the amounts returned by debtors, and granting the assessee an opportunity to present its case. The decision aimed at ensuring a fair and comprehensive reassessment process. Overall, the judgment highlighted the importance of procedural compliance, proper documentation, and adherence to legal requirements in conducting assessments, especially in cases involving disputed notices and timelines. The decision underscored the significance of due process and fairness in tax assessments, necessitating a reevaluation of the assessment in question to address the raised issues effectively.
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