(1.) HEARD learned counsel for the petitioner.
(2.) THE Commissioner of Income-tax, Jaipur, issued a show-case notice to the assessee, Shri Subeer Singh Tamra, under section 263 of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), in respect of the assessment years 1977-78 and 1978-79 to show cause why the assessments made by the Income-tax Officer under section 143(1) of the Act for the aforesaid two years may not be reopened on the ground that they were erroneous and were prejudicial to the interests of the Revenue. THE assessee did not appear and an ex parte order was passed by the Commissioner of Income-tax on September 10, 1981, setting aside both the assessments and directing the Income-tax Officer to take de novo proceedings from the stage of the return after making the necessary inquiry.