1988 (2) TMI 30

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..... erein the initiation of the proceedings under section 147 of the Income-tax Act (briefly " the Act ") was questioned. The main point of attack by learned counsel for the petitioner was that the Income-tax Officer had no jurisdiction to initiate proceedings on the facts and circumstances of the case. While disposing of the writ petition, the learned single judge has held that there is a prima facie .....

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..... al with liberty to the appellant to raise all questions that are open to it under law before the assessing authorities, including the question of jurisdiction or of the conditions precedent for invoking the provisions under section 147 of the Act. In other words, the position would be as if the petitioner company had not filed any writ petition. Civil Miscellaneous No. 220 of 1987 is dismissed as .....

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