LAWS(PAT)-2011-5-160

KUMAR STORES Vs. COMMISSIONER OF INCOME TAX

Decided On May 20, 2011
Kumar Stores Appellant
V/S
COMMISSIONER OF INCOME TAX Respondents

JUDGEMENT

(1.) Heard learned counsel appearing on behalf of the Petitioner and the learned counsel appearing on behalf of the Respondents.

(2.) With the consent of the parties, this matter has been taken up for disposal at the stage of admission itself.

(3.) The sole question which arises for consideration before this Court is as to whether the impugned order of assessment passed by the Respondent Income Tax Officer in purported exercise of power vested under Section 147 of the Income Tax Act, 1961, (hereinafter referred to as 'the Act'), on the reasons recorded under Section 148 of the Act and the revisional order passed under Section 264 of the Act, satisfies the parameters enabling such exercise.