TMI Blog1993 (11) TMI 45X X X X Extracts X X X X X X X X Extracts X X X X ..... ears from July 1, 1980, to June 30, 1981 (assessment year 1982-83) and from July 1, 1981, to June 30, 1982 (assessment year 1983-84), the petitioner had submitted the returns and audited books of account. The returns submitted by him were not accepted by the third respondent and he issued exhibits P-1 and P-2 reassessment notices dated May 24, 1987, and May 25, 1987, for the assessment years 1982- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e tax for a period much anterior to it. It is also submitted by counsel for the petitioner that the inspection was without notice and hence at any Tate no reliance can be placed on the same. The learned Government Pleader submitted that the assessments were completed not solely on the basis of the inspection report but taking into consideration the previous returns filed by the petitioner and othe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... diminished year by year. The third respondent examined the contentions raised by the petitioner and reduced the yield to that of 1981-82, i.e., 14,055 kgs. instead of 17,020 kgs. Accordingly, the proposal was modified. While making exhibit P-6 assessment the data furnished by the petitioner for the years 1978-79 to 1982-83 were considered. Considering the income conceded and fixed for earlier ye ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in one year and an identical matter or question comes up for consideration in the subsequent year, the decision rendered in the previous year will be certainly "good and cogent evidence" in the subsequent year when a similar question falls to be determined. In the above decision, it is also held that so long as the best judgment assessment cannot be found to be arbitrarily made the High Court cann ..... X X X X Extracts X X X X X X X X Extracts X X X X
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