- (1.) THIS writ petition impugns a notice dated December 31, 1982. issued to the petitioner by the first respondent under section 148 of the Income-tax Act proposing to reopen her income-tax assessments for the assessment years 1979-80, 1980-81 and 1981-82, because he had reason to believe that her income chargeable to tax had escaped assessment within the meaning of section 147.
(2.) THE petitioner was born in Tanzania and came to India upon her marriage in November, 1975. A search was conducted of her premises and safe deposit lockers in January, 1982, and gold ornaments and jewellery were seized. On April 14, 1982, an order was made by the first respondent under section 132 (5) retaining the seized assets and ordering the addition of an amount of Rs. 3,40,190 credited to the petitioner's savings account on the ground that it was an unexplained receipt. On December 7, 1982, an order was made under section 132 (11) of the Act by the Commissioner of Income-tax (Investigation) which accepted the petitioner's explanation in respect of the seized articles as also the sum of Rs. 3,40,000. The order dated April 14, 1982, was, accordingly, vacated.
(3.) ON April 21, 1982, and September 21, 1982, the petitioner was issued notices to file wealth-tax and income-tax returns for the assessment years 1979-80 to 1982-83 and 1982-83, respectively, by the Income-tax Officer/wealth-tax Officer of Survey Circle.;