GREAT ARTS (P) LTD. Vs. ITO

JUDGEMENT

(1.) BY this writ petition the petitioner has challenged the validity of notice dated 27 -3 -1976, issued under Sec. 148 of the Income Tax Act, 1961 (hereinafter referred to as the Act), proposing to reassess the income of the petitioner for the assessment year 1967 -68, on the ground that income chargeable to tax had escaped assessment within the meaning of Sec. 147 of the Act.

(2.) THE petitioner has also challenged a communication dated 29 -10 -1979, issued by Income Tax Officer, Company Circle -XIV, vide which the said officer had conveyed that the reasons leading to the initiation of reassessment proceedings, were not required to be communicated by relying on the Supreme Court decision reported as S. Narayanappa and Ors. v/s. : [1967]63ITR219(SC) .

(3.) AFTER show -cause notice was issued in the writ petition, the respondents filed a counter -affidavit to which has been annexed, as Annexure A, the statement of reasons recorded by the Income Tax Officer, Company Circle -XIV on the file, while requesting for permission of the competent authority for reopening the case for the assessment year 1967 -68. The recorded reasons may be quoted for convenience of reference :