GOPAL LAL DHAMANI Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) ALL the abovenumbered revision petitions involve a common question of law and, therefore, it will be in the interest of justice to deal with them by a common order. It is also necessary to deal with them under a common order because the complaint out of which the abovenumbered revision petitions arise was filed after the proceedings under Section 132(5) of the Income-tax Act, 1961 ("the Act"), were finalised and they arose out of a raid organised on May 20, 1983, by the Income-tax Officer, Central Circle-3, Jaipur.

(2.) THE common question of law which is involved in all the cases is as to whether for filing a complaint under Section 276C of the Act, it is necessary that there should be a regular assessment under the Act, against the assessee.

(3.) THEIR Lordships further observed as under (p. 700):