Andhra Pradesh Court May 1971 Judgments

Bajranglal Beria Vs. Income-tax Officer, b Ward, Companies Circle, Dib ...

Court: Andhra Pradesh

Reported in: [1972]85ITR335(AP)

GOSWAMI C.J. - This judgment will govern all the above civil rules as an identical question of law is involved with regard to the jurisdiction of the Income-tax Officer to issue the impugned notice under section 147 of the Income-tax Act, 1961, for four assessment periods against the petitioner-assessee.The only point of difference in the four cases is the quantum of income that is alleged to have escaped assessment. It is therefore sufficient to state the facts of Civil Rule No. 63 of 1967 which were relied upon by the counsel for both parties during the course of the hearing. The assessment year in this case is 1954-55. In this case there was an earlier assessment under section 23 (4) of the old Income-tax Act which was later cancelled under section 27 and the assessee submitted his return for the assessment year 1954-55 on 27th January, 1959. Notices under section 23 (2) were served and complied with by the assessee who produced his accounts for the year 2010 R. N. ending 10th of Ap...