2009 (11) TMI 47

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..... claim made in respect of Keyman Insurance Policy on the life of Shri Sanjeev Suri was not allowable deduction as Shri Sanjeev Suri was partner of the firm. On account of the mistake committed in status of the aforesaid Shri Sanjeev Suri, the assessment is sought to be re-opened – held that - argument that the show cause notice and proceedings thereafter are without jurisdiction, is wholly without .....

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..... his Court with a prayer for quashing notice dated 5.3.2009 (P-4), issued under Section 148 of the Incometax Act, 1961 (for brevity, 'the Act') by the Assessing Officer, Jalandhar. The reasons for issuance of notice have also been recorded as is evident from the perusal of the order dated 5.3.2009 (P-5). The petitioner has already raised objections dated 11.6.2009 (P-6) against issuance of notice .....

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..... t to be re-opened. Having heard learned counsel for the petitioner at some length we are of the view that the writ petition is wholly misconceived and the argument that the show cause notice and proceedings thereafter are without jurisdiction, is wholly without merit. It is not a case where the department is proceeding on the basis of change of opinion. The department appears to be well within i .....

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