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S. Narayanappa & Ors vs Commissioner Of Income-Tax, Bangalore on 27 September, 1966

In S. Narayanappa v. CIT __________ https://www.mhc.tn.gov.in/judis/ Page 12 of 20 W.P.Nos.947 & 948 of 2012 (1967) 63 ITR 219, it was noted by the apex court that the expression "reason to believe" in Section 147 does not mean purely a subjective satisfaction on the part of the Assessing Officer, the belief must be held in good faith; it cannot be merely a pretence. It is open to the court to examine whether the reasons for the belief have a rational nexus or a relevant bearing to the formation of the belief and are not extraneous or irrelevant for the purpose of the section. To that limited extent, the action of the Assessing Officer in initiating proceedings under Section 147 can be challenged in a court of law."
Supreme Court of India Cites 7 - Cited by 392 - V Ramaswami - Full Document
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