K.S.HEGDE, P.JAGANMOHAN REDDY
Union Of India – Appellant
Versus
Messrs. Rai Singh Dev Singh Bist – Respondent
Mr. S. C. Manchanda, Sr. Advocate (M/s. B. B. Ahuja, S. P. Nayar and R. N. Sachthey, Advocates with him), for appellants M/s. N. D. Karkhanis, Rameshwar and Miss Seita Vaidialingam, Advocates of M/s. Rajendra Narain & Co., Advocates, for Respondents.
Judgment
HEGDE, J. :- These appeals by certificate arise from several writ petitions filed by the H.U.F. M/s. Raj Singh s Deb Singh Bist and its Karta Thakur Mohan Singh Bist, challenging the validity of certain notices issued under Section 34 (1) (a) of the Indian Income-tax Act, 1922 (in short the Act) by the Income-tax Officer, Central Circle Delhi. The High Court of Delhi allowed these writ petitions and quashed the impugned notices. Hence these appeals.
2. The assessee in these cases in an H.U.F. The assessment years with which we are concerned in these appeals range from 1942-43 to 1953-54. The assessee filed its return for these years in due time. The assessee s account-books showed considerable cash credits in the name of the brother-in-law of the 2nd respondent, the Karta of the H.U.F. Those alleged creditors were living in Nepal. The account books also showed certain credit entries in the name of Rana Anand Nar Singh alleged to
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