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1971 (11) TMI 21

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..... n which the Income-tax Officer has acted and this is not a case where the notice was issued without jurisdiction or without statutory authority - - - - - Dated:- 1-11-1971 - Judge(s) : RAMA PRASADA RAO. ORDER RAMAPRASADA RAO J.-The petitioner took on lease a tea estate known as " Rajarajeswari Estate " measuring about 54.41 acres for a period of ten years from its owners by lease-deed date .....

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..... as to why the earlier order for the year 1965-66 should not be reopened as there was an escapement of assessment while the assessment order was passed for that year. On receipt of this notice the petitioner has come up to this court for the issue of a writ of prohibition stating that, as the earlier officer allowed the deduction, the officer who took a different view for the later year or years ca .....

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..... hat that matter required re-scrutiny in view of certain decisions of the Supreme Court and other material. It was in such a situation that the respondent initiated the proceedings under section 147(b) on the basis of information made available to him both on record and otherwise. That cannot be said to be an unreasonable attitude on the part of the respondent. Certainly, it cannot be said that the .....

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