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Issues:
1. Initiation of proceedings under section 148 2. Clubbing of share income of minor sons in the hands of the assessee under section 64(1)(iii) 3. Levy of interest under section 139(8) Issue 1: Initiation of proceedings under section 148 - The first ground challenging the initiation of proceedings under section 148 was not pressed during the hearing and was treated as dismissed for the assessment year 1977-78. - The same ground was also not pressed for the assessment year 1978-79 and was accordingly treated as dismissed. - For the assessment year 1983-84, the ground regarding the initiation of proceedings under section 148 was not pressed and was treated as dismissed. Issue 2: Clubbing of share income of minor sons under section 64(1)(iii) - The case involved the clubbing of share income of minor sons in the hands of the assessee under section 64(1)(iii) of the Income Tax Act. - The assessee argued that the amendment to section 64(1)(iii) was not applicable as the minor sons were admitted to partnership firms before the effective date of the amendment. - The Departmental Representative contended that the intent of the law was to club the profits of minors in the hands of the individual after a specific date, regardless of when they were admitted to partnership. - The Tribunal held that the income of the minor sons from their admission to partnership firms was rightly clubbed in the hands of the assessee. - The Tribunal distinguished the case law cited by the assessee, emphasizing that the facts of those cases were different from the present case. - The Tribunal concluded that the clubbing of income under section 64(1)(iii) was justified and rejected the ground challenging it. Issue 3: Levy of interest under section 139(8) - The assessee contested the levy of interest under section 139(8) for the assessment years in question. - The Tribunal referred to various decisions and held that interest under section 139(8) should not be charged in reassessment proceedings. - The Tribunal directed the Assessing Officer to delete the interest charged under section 139(8) for all relevant assessment years. - The Tribunal allowed the appeals in part, based on the findings related to the levy of interest under section 139(8). In conclusion, the Tribunal addressed the issues of initiation of proceedings under section 148, clubbing of share income of minor sons under section 64(1)(iii), and levy of interest under section 139(8) in a comprehensive manner. The Tribunal dismissed the grounds related to initiation of proceedings under section 148, upheld the clubbing of income of minor sons in the hands of the assessee, and directed the deletion of interest charged under section 139(8) for all relevant assessment years.
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