Supreme Court · 1976 INSC 89 · Decided 30 March 1976
Income Tax Officer, I Ward, DIST. Vi, Calcutta & ORS. v. Lakhmani Mewal Das
- Court
- Supreme Court of India
- Citation
- 1976 INSC 89 · [1976] 3 S.C.R. 956
- Case number
- CIVIL APPEAL No. 2526/1972
- Decided
- 30 March 1976
- Bench
- HANS RAJ KHANNA, P.K. GOSWAMI (2-judge bench)
- Outcome
- Dismissed
- Case type
- Civil
- Acts & sections cited
- Constitution Article 226; Income Tax Act Section 148, 23(3)
Headnote
/nconie Tax Act, 1961--,S. 148-Scope of-Words & Phrases-"Reason to believe" meaning of 'ratio11al nexus'-What postulates. Jn March 1967, a[ter obtaining the satisfaction of the Commissioner !he appel1ant issued a notice under s. 148 of the ln~o~e Tax Act. 1961 stating that he had chargeable to t~ for the assessment year 1958-59 had escaped assessment. The respondent reph- ed that the I.T.0. had no competence or jurisdiction to reopen the assessment under s. 147 of the Act on a mere change of opinion. Since there \vas no reply from the appellant, the respondent moved the
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