Pinaki Chandra Ghooe, J. - (1.) The subject-matter of challenge in the writ petition is a notice dated March 22, 1978, issued by the income-tax authorities for the assessment year 1969-70 under Section 148 of the Income-tax Act, 1961 (hereinafter referred to as "the said Act"). According to the petitioner, the notice did not disclose the reasons for initiation of the proceedings.
(2.) It is also submitted that the assessment of the petitioner for the assessment year 1969-70 was made under Section 143(3) of the said Act, on February 28, 1972. The said assessment was set aside on appeal by the Appellate Assistant Commissioner by his order dated June 20, 1972, and the assessment was again made on March 28, 1973.
(3.) The controversy arose in the matter in respect of allowance of grinding charges for a sum of Rs. 5,34,349.55 paid by the petitioner to one Allied Industries and Commercial Corporation of Calcutta. According to the petitioner, the same were allowed in the assessment made on February 28, 1972, as well as in the subsequent assessment made on March 28, 1973. It is further pertinent to mention here that the appeals and other proceedings were not in respect of the said deduction allowed in the assessment by the said authorities.;