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1 - 10 of 18 (0.21 seconds)Section 34 in Gold (Control) Act, 1968 [Entire Act]
Section 35 in The Income Tax Act, 1961 [Entire Act]
Estate Duty act, 1953
Section 33B in The Income Tax Act, 1961 [Entire Act]
Ramkrishna Ramnath vs G. Lakshmi Narasimhan, Income-Tax ... on 27 February, 1969
The correct significance of the words "external source" has been explained by the Bombay High Court in Rarnkrishna Ramnath v. Income-tax 'Officer, (1970) 77 I. T.R. 995, in the following words :- "THEinformation which is relied upon by the Income-tax Officer for issuing the notice under section 148 must be information which he has obtained aliunde and not merely by looking at his own order made in the proceeding for a subsequent year."
Jawahar Lal Mani Ram vs Commissioner Of Income-Tax, U. P. on 9 May, 1962
It is no doubt true that no case has come to our notice in which proceedings under section 147(b) of the New Act were initiated on the basis of the information or finding of a body or authority other than the Supreme Court, the High Courts, the Tribunal or the appellate authorities under the Income-tax Act. But, at the same time. none of these decisions has in so many words restricted .the scope of "external source" to courts or the tribunals under the Act. The Tribunal has referred to the decision of the Allahabad High Court in Jawahur Lal Mani Ram v. Commissioner of Income-tax (1963) 48 I.T.R. 837 in support of its view that only judicial decisions of the Appellate Assistant Commisisoner or the Income-tax Appellate Tribunal are information within the meaning of expression "external source" used in section 34(l)(b) of the Old Act. We have carefully read the report of the judgment of the Allahabad Hi"h Court, but we find that while the High Court has held that decisions of A.A.C. or the Tribunal constituted information within the meaning of section 34(1) (b) of the Old Act, it has no where held that only such decisions constituted such information. Therefore, in our view, the expression "external source" used by the Supreme Court in A. Raman and Co; s case cannot be restricted to opinions expressed or findings given by Courts of law or the Tribunal or other authorities under the Income-tax Act.