1985 (5) TMI 91

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... n 146 of the Income-tax Act, 1961 ('the Act') application for reopening of the case made by the assessee before the ITO. 2. The learned departmental representative relied on the judgment in the case of CIT v. Gupta Sons (P.) Ltd. [1984] 146 ITR 506 (MP) against which the learned counsel for the assessee relied on the judgment in Ebrahim Soofi v. ITO [1979] Tax 52(6)-10 (Bom.-Trib.). Besides, h .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... on Act, 1963, and the matter was in respect of acquisition proceedings. Their Lordships held in the said case that section 5 would be applicable unless it is specifically excluded by any Act. On parity of reasons available in the said decision which is from the Punjab and Haryana High Court and as we are sitting at Chandigarh, we are obliged to follow the Punjab and Haryana High Court and confirm .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X