Further, the writ petition averred that the respondents had already issued a numberice to the appellant under Section 148 of the Income tax Act, 1961 for the same assessment year and that the appellant had, in companypliance therewith, filed a return.
It was averred in the writ petition that the first respondent had failed to disclose the reasons that he was obliged to record under Section 148 2 for reopening the assessment.
The numberice alleged that the first respondent had reason to believe that the appellants income chargeable to tax for the assessment year 1986 87 had escaped assessment and that, therefore, the first respondent proposed to assess the appellants income for that assessment year.
By the writ petition the appellant challenged the validity of a numberice issued to it by the first respondent under Section 148 of the Income tax Act, 1961.
Under appeal by special leave is an order of a Division Bench of the High Court at Bombay, sitting at Panaji.
P. Bharucha, Syed Shah Mohammed Quadri and N. Santosh Hegde, JJ.
By that order the writ petition filed by the appellant was summarily dismissed.
