MANGILAL Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) BY filing this writ under article 226/227 of the Constitution of India, the petitioner (assessee) seeks to challenge the notices issued under Section 147/148 of the Income Tax Act, 1961 by the Assessing Officer (R -1) dated May 29, 2001, collectively marked as (annexures P -6 to P -11).

(2.) THE impugned notices relate to the assessment years 1993 -94, 1997 -98, 1998 -99, 1999 -2000 and 2000 -01.

(3.) ACCORDING to petitioner, on facts pleaded in the writ and keeping in view the back ground of the case relating to the assessee and in particular his assessment as an individual, the impugned notices are bad in law and hence, deserve to be quashed whereas according to Income Tax Department, the notices issued are legal and proper having been issued in conformity with the factual and legal requirement of the twin sections (147 and 148).