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TMI Blog2007 (2) TMI 659X X X X Extracts X X X X X X X X Extracts X X X X ..... mritsar Bench, Amritsar arising out of the order dated 30-6-1989 passed by it in ITA No. 375 ASR of 1987 in respect of the assessment year 1967-68: Whether the Tribunal was legally right in holding that reassessment proceedings under section 147(a) of the Act were invalid because in the consequential assessment no addition came to be made in respect of income which was stated to have had escap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessing Officer, the assessee had deposited the aforementioned amount with one Daulat Singh which is shown from the material recovered from his (Daulat Singh) premises. The Appellate Assistant Commissioner while passing order under section 250(6) of the Act categorically held that the reasons recorded for re-opening assessment under section 147(a) of the Act were different and the assessment ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hri Daulat Singh. It is not known as to how it struck the ITO after the notice under section 148 had been issued that the amount of ₹ 42,800 was also required to be added to the income of the appellant. Interestingly enough, no addition on account of the appellant s share in the unaccounted income of the said company has been made to the income for which purpose the original assessment was r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITR 2971. The view of the Hon ble Supreme Court emerges from the following observations: .... in proceedings under section 147 of the Act, the Income-tax Officer may bring to charge items of income which had escaped assessment other than or in addition to that item or items which have led to the issuance of the notice under section 148 and where reassessment is made under section 147 in respe ..... X X X X Extracts X X X X X X X X Extracts X X X X
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