9911796707
TMI Blog1991 (1) TMI 111X X X X Extracts X X X X X X X X Extracts X X X X ..... ection 148 read with section 147(b) of the Income-tax Act, 1961, relating to the assessment year 1975-76. The petitioner had submitted his return for the said assessment year on the basis of which assessment was made on April 28, 1976. The impugned notice had been issued on March 28, 1980. The notice, of course, does not disclose the information on the basis of which it was issued. Be that as it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reasons as required by section 148(2) of the Act, had issued the impugned notice to the petitioner." With a view to satisfy ourselves as to the validity of the impugned notice, we called upon learned counsel to produce the relevant record before us including the reasons recorded by the Income-tax Officer as contemplated by sub-section (2) of section 148. We have perused the same. We are of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is to rectify his order. We do not wish to go into the question, whether it is not permissible for this court to sustain the notice under section 154 of the Act to the extent it can be done. That question can be examined in an appropriate case. Indeed, the mistakes committed by the Income-tax Officer in this case could also have been rectified by the Commissioner under section 263 of the Act. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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