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Calcutta Discount Company Limited vs Income-Tax Officer, Companies ... on 1 November, 1960

23. A large number of decisions have been referred to us from the Bar, but we need not enter into the question of their applicability in the instant cases, as it is considered that the Calcutta Discount case is the true guide for disposal of such matters. Furthermore, we may observe that income cannot be held to have escaped assessment within the meaning of Section 147(a) merely on the ipse dixit of the Income-tax Officer. It is for him to establish that he had reasons to believe in the first instance that there was non-disclosure of income. Such reasons are absent in his notes, and, accordingly, it is hardly possible to hold that the notices come within the ambit of the said clause.
Supreme Court of India Cites 13 - Cited by 1681 - K C Gupta - Full Document
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