2000 (11) TMI 77

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..... ncome-tax Act, 1961, dated March 23, 1989 (annexure J), by the Income-tax Officer to the petitioners for the assessment year 1984-85. The challenge to the notice under section 148 ibid is, inter alia, on the ground that issuing of notice to an association of persons is bad, that it does not record any reasons, that it is issued without application of mind, that assuming some reasons are recorded .....

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..... opies of the reasons recorded by the Assessing Officer and then the sanction accorded by the Deputy Commissioner (annexure R4) for issuance of notice. None for the petitioner. None for the respondents. Record perused. In my opinion, no ground is made out by the petitioner to successfully assail the impugned notice issued under section 148 ibid. I have perused the return and in more particular .....

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..... w. Since I am satisfied with the legal requirements that were necessary for issuance of notice under section 148 of the Act and that the factual reasons detailed in the annexure which were duly approved by the Deputy Commissioner. It is not necessary for me to narrate those factual reasons in the judgment. In view of the aforesaid discussion, I do not find any merit in this writ. It is dismiss .....

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