section.
(2) The Income-tax Officer shall, before issuing any notice under this section, record his reasons for doing so."
Section 297 ... notices under Section 148 and that the reassessments were completed under Section 147 of the Act of 1961, by virtue of Section 297
read with Section 150(2) and Section 153 , Explanation 2, of the said Act,
Counsel for the assessee contended that Section 297 ... Income-tax Act, 1961 , Clause (a) of Sub-section (2) of Section 297 applied to this case because reassessment was a part and continuation
These are Clauses (a), (b), (c) and (d) of Sub-section (2) of Section 297.
17. In this connection, on behalf of the Revenue reliance ... Section 66A(2) of the Act which was completely obliterated by reason of the provision for repeal contained in Sub-section (1) of Section 297
said section had ceased to be in force after it was repealed by sub-section (1) of section 297 of the Income ... section clearly embodies a "proceeding for the assessment" as contemplated in clause (a) of sub-section (2) of section 297. It seems
liabilities by virtue of the different clauses of Sub-section (2) of Section 297 of the I.T. Act, 1961, then undoubtedly the right ... repeals the Indian I.T. Act, 1922 , and Sub-section (2) of Section 297 provides for what would happen in certain specified cases notwithstanding
contained in an order under Section 31 , Section 33 , Section 33-A Section 33-B , Section 66 or Section 66-A.'
I have stated ... Income-tax . This case dealt with Clause (g) of Sub-section (2) of Section 297 of the 1961 Act. The relevant part thereof runs
counsel for the respondents Section 155 does not deal with rectification as such and is independent of Section 297 ... income of the firm under Section 31 , Section 33 , Section 33A , Section 33B , Section 66 or Section 66A that the share of the partner
comparative analysis of Section 28(1) of the repealed Act and Section 271 of the Act that the provisions of Section ... notice under Section 271 of the Act in the present case, I should hold that the provisions of Section 297(2)(g) are violative
purposes of clauses (a) and (b) of Sub-section (2) of Section 297 of the Income-tax Act, 1961 (XLIII of 1961) (hereinafter referred ... repealing Act. -- In cases covered by Clause (b) of Sub-section (2) of Section 297 of the repealing Act, the assessments shall be made, inter
treated as proceedings under Section 35 of the Act of 1922, in view of the. provisions of Section 297(2)(d)(i) of the Income ... authority to and had duly proceeded under Section 154 of the Income-tax Act, 1961. Under sections 297(2)(a) and 297