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1 - 8 of 8 (0.51 seconds)Section 148 in The Income Tax Act, 1961 [Entire Act]
Section 153 in The Income Tax Act, 1961 [Entire Act]
Ramkrishna Ramnath vs G. Lakshmi Narasimhan, Income-Tax ... on 27 February, 1969
In support of this submission reliance was placed on a decision of the Bombay High Court in Ramkrishna Ramnath v. ITO [1970] 77 ITR 995. With respect to their Lordships of the Bombay High Court, who decided that case, we are not inclined to take that view. In our opinion, what is required is that the information received must be as to fact or law, it must relate to a matter bearing on the assessment and it must be derived from an external source.
Maharaj Kumar Kamal Singh vs The Commissioner Of Income-Tax, Bihar & ... on 1 October, 1958
In Maharaj Kumar Kamal Singh v. CIT [1959] 35 ITR 1 (SC), when called upon to construe the corresponding provision as contained in Section 34(l)(b) of the 1922 Act, the Supreme Court held that the word "information" means not only facts or factual material but includes also information as to the true and correct state of the law.
Section 34 in The Income Tax Act, 1961 [Entire Act]
Commissioner Of Income-Tax, Gujarat vs A. Raman & Company on 18 July, 1967
Thereafter, in CIT v. A. Raman & Co. [1968] 67 ITR 11 (SC), this expression as occurring in s. 147(b) was held to signify instruction or knowledge derived from an external source concerning facts or particulars or as to law, relating to a matter bearing on the assessment. This definition has been reaffirmed in subsequent cases though in some cases a slight departure has also been made.
Narayan Bhagwantrao Gosavi Balajiwale vs Gopal Vinayak Gosavi And Ors. on 22 September, 1959
tion the other piece of evidence which was in the form of the report of the Board of Experts. The question would be as to whether the formation of belief by the ITO on this basis was reasonable or not. We do not find any reason to hold that the formation of belief was in any way unreasonable. The legal value of an admission is that it is the best evidence that an opposite party can rely upon, and though not conclusive, is decisive of the matter, unless successfully withdrawn or proved erroneous: vide Narayan Bhagwantrao Gosavi Balajiwale v. Gopal Vinayak Gosavi, AIR 1960 SC 100. The admission contained in the notice of Satish Chandra had not been withdrawn by the assessee nor had any attempt been made to prove that it was erroneons. On the basis of this admission and the expert's report, the assessment was framed for the assessment year 1966-67 and certainly on the basis of that the ITO could reasonably form a belief that the income for the assessment year 1965-66 had escaped assessment. On this view of the matter, we are not prepared to agree with the assessee's counsel that the reopening of the assessment was as a result of a mere change of opinion.
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