COMMISSIONER OF INCOME TAX Vs. RAJATHA JEWELLERS

JUDGEMENT

(1.) THE Revenue has sought this reference under Section 256 (1) of the IT Act, 1961 (for short hereinafter referred to as "the Act" ). The substantial questions of law referred by the Tribunal for adjudication are as under : 1. Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the notice issued under Section 148, requiring the assessee to file a return within 30 days of the receipt of the same, was invalid ?

(2.) WHETHER, on the facts and in the circumstances of the case, the Tribunal was right in holding that the reassessments made for these years were invalid in law because of the defective notice ?

(3.) WHETHER, on the facts and in the circumstances of the case, the Tribunal was right in holding that the value of 18. 621 kgs. of gold, brought by K. V. Jayaprakash into the firm, did not constitute stock-in-trade of the assessee-firm ?