1982 (7) TMI 196

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..... 970-71. The facts of the case show that a notice under s.148 was issued to the assessee on 16th June., 1973 for submission of the return for the year 1970-71 and notice was also issued under s. 142(1) of the IT Act, both of which were not complied with by the assessee, but it appears, that at the instance of the representative on 20th Dec., 1976 time was allowed to the assessee to file the return .....

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..... ts and heard the parties. While it is the assessee's contention that a petition under s. 146 for reopening the assessment has been filed which has not been disposed of, the decision is not able to state whether such a petition was in fact filed or not from the records available to him. The orders of the departmental authorities also does not indicate whether any show cause notice was issued and wh .....

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..... return in response to notice under s.148 of the Act. The ld. Representative for the assessee submitted that without going into the various disputed facts as to whether the assessee had filed a petition under s. 146 or not or whether there was any reasonable cause for the assessee's failure to submit the return, he would confine his claim to reduction of quantum of penalty with reference to the ext .....

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