9911796707
TMI Blog1987 (7) TMI 30X X X X Extracts X X X X X X X X Extracts X X X X ..... Revenue is the respondent in both these cases. We are concerned with the assessment years 1976-77 and 1977-78. Identical questions arise for consideration in both the cases. The petitioner (assessee) is a firm. The assessments made for these two years initially were reopened under section 147(b) of the Income-tax Acton the ground that interest on the amounts diverted to sister concerns, which oug ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Raman Co. [1968] 67 ITR 11 (SC) and Salem Provident Fund Society Ltd. v. CIT [1961] 42 ITR 547 (Mad), the Appellate Tribunal held that the Income-tax Officer got information that there were interest free advances to the sister concerns and there were new materials which prompted the reopening of the assessments. In these circumstances, the reopening was held to be valid. The matter was restore ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d and covered by section 147(b) of the Act. We are satisfied that the decision of the Appellate Tribunal is right. We are of the view that apart from the fact that the questions formulated for being referred to this court are pure questions of fact, there is no case for the petitioner even on the merits. Further, the petitioner formulated one question under section 256(1) of the Act praying to the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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