PRABHAT SAW MILLS AND TIMBER MERCHANTS Vs. INCOME TAX OFFICER
INCOME TAX APPELLATE TRIBUNAL
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S. Balasubramanyam, Judicial Member -
(1.) THE source of these appeals by the assessee is the reassessments made for the years 1987-88 and 1988-89. THEy were heard together since the grounds are common.
(2.) The assessee is a firm doing business. On the basis of a return filed the original assessments had been made under Section 143(1) for both these years. The assessee had claimed that certain credits in the accounts were loans taken from certain persons. The firm had also paid interest to those creditors and deduction had been sought in that behalf. Naturally this had been accepted in the original assessments made under Section 143(1).
During the course of assessment for 1989-90 the Income-tax Officer had occasion to examine the cash credits. He had addressed a letter in this behalf to the assessee on 10-8-1990 which had been received by the assessee on 14-8-1990.
(3.) ON 22-8-1990 the Income-tax Officer recorded his reasons of belief as he was of the view that income chargeable to tax had escaped assessment on account of certain factors and he had decided to reopen the assessments. A record was made on the aforementioned date and he reopened the assessments.;
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