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TMI Blog1999 (3) TMI 59X X X X Extracts X X X X X X X X Extracts X X X X ..... ome-tax Officer informed him that he had "reason to believe that-income in respect of-assessment years 1994-95 and 1995-96, has escaped assessment within the meaning of section 147 of the Income-tax Act, 1961". These notices related to two years. The reasons were communicated vide documents, copies of which have been produced as annexures P-31 and P-32. It was pointed out that during the period fr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 69,538 and Rs. 14,000 have been deposited by the petitioner. According to Mr. Mittal, the deposits had been made on behalf of Mr. Dharam Pal. Is it really so ? Who gave the . money ? What was the source ? These are matters which have to be gone into by the assessing authority. At the present moment, it cannot be said that the assessing authority could not have any reason to believe that some incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... v. CIT [1959] 36 ITR 407 (Punj); Sheo Nath Singh v. AAC of I. T. [1971] 82 ITR 147 (SC) ; Income-tax Officer v. Lakhmani Mewal Das [1976] 103 ITR 437 (SC) and Asoke Kumar Sen v. ITO [1981] 132 ITR 707 (Delhi). It is undoubtedly correct that proceedings under section 147 can be initiated only when the assessing authority has reason to believe that income chargeable to tax has escaped assessment. I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the matter calls for no interference. Mr. Mittal states that in C. M. No. 4673 of 1999, the petitioner has given an explanation with regard to the source of income, etc. This is a matter, which shall be considered by the competent authority. We do not wish to express any opinion lest the interest of the petitioner or the Revenue may be prejudicially affected. No other point has been raised. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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