COMMISSIONER OF INCOME TAX Vs. SURESH CHANDRA MITTAL

JUDGEMENT

(1.) THE Income-tax Appellate Tribunal has made this reference and has filed statement of the case, for opinion of this court on the following question :

(2.) SHORN of all details, it emerges that the assessee first filed his returns for the assessment years 1983-84, 1984-85, 1985-86 and 1986-87 showing income ranging between Rs. 10,000 and Rs. 12,000. Later action under Section 132 was taken against him which led to reopening of the assessment. A notice under Section 148 was served on him, and pursuant thereto he filed revised returns of income for these assessment years showing higher income. Eventually the assessment orders were passed and the returns submitted regularised under Section 148.

(3.) THE Tribunal also placed reliance on the Supreme Court judgment in Sir Shadilal Sugar and General Mills Ltd. v. CIT, 1987 168 ITR 705, in support holding as under (page 713) :