2019 (12) TMI 580

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..... respondent No.2 under Section 148 of the Income- Tax Act, 1961 (for short, 'the Act of 1961'), the petitioner has preferred the present writ petition under Article 226 of the Constitution of India. Assailing the impugned notice, Mr. Bhandawat invited Court's Attention towards the notice dated 28.03.2018, issued by the respondent No.4 and submitted that the reasons recorded before issuance of the .....

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..... advanced by Mr. Bhandawat to be frivolous. The earlier notice under Section 138 of the Act of 1961 had been issued for the Assessment Year 2011-12, inter alia referring to certain loose papers recovered from one Mr. Mahendra Kankaria; the proceedings in furtherance of the earlier notice, after taking response from the petitioner, have culminated into an assessment order under Section 147/143(3) o .....

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..... f 1961 has been initiated for the same reasons, is factually correct, but the same does not render the proceedings to be illegal. Since the proceedings are for different assessment years, the argument so zealously advanced, is untenable. So far as the satisfaction of the concerned Assessing Officer and the Commissioner, Income Tax is concerned, a perusal of the pages Nos.65 to 69 available on re .....

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