9911796707
TMI Blog1982 (9) TMI 132X X X X Extracts X X X X X X X X Extracts X X X X ..... ven u/s 17(1) (b) was ab initio void. The facts are that the assessee was a partner in the firm M/s Hazarimal Milapchand, on whom the assessment had been made on 29th January, 1977 for the asst. yr. 1975-76. The said firm showed a gross profit rate of 24.46%. Assessment on the assessee was originally made on 18th July, 1977. To find out the interest of the assessee in the firm, the value of the cl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... believe that the share of the assessee, i.e., Rs. 1,41,721 in the difference of Rs. 4,72,404, had escaped assessment according to him. On appeal, the AAC relying on his order passed in the case of Mannalal Surana, belonging to the same group, held that no valid reasons were there to reopen the assessment. 2. We have carefully heard Shri H. Singh, ld. Deptl. Rep, and Shri Ranka, ld. counsel for t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e correct facts were discovered only after a good deal of research and investigation of the firm s assessment. We asked the revenue time and again to set out the circumstances, which may establish that though the firm s order was available at the stage of the original assessment of the assessee, but some research on that order had been done at a subsequent stage. No such material has been put by t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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