- (1.) THIS appeal is directed against an order dated March 22, 2006, whereby the hon'ble first court has dismissed the writ application filed by the writ petitioner challenging the order of the Commissioner of Income -tax dated December 27, 2005, made under Section 127 of the Income -tax Act, 1961 (hereinafter rejected to as 'the said Act').
(2.) THE ground on which the order is challenged is that no reason was disclosed by the authorities in the show -cause notice dated November 25, 2005. Mr. Pratap Chatterjee, learned Counsel appearing before us on behalf of the petitioner, contended that non -disclosure of reason in the show -cause notice amounted to denial of reasonable opportunity of hearing as contemplated under the provisions of Section 127 of the said Act. He further relied upon the decisions reported in Chotanagpur Industrial Gases P. Ltd. v. CTT : [1998]233ITR377(Cal) and Ajantha Industries v. CBDT : [1976]102ITR281(SC) in support of his such contention.
(3.) WE have perused the said show -cause notice which is also set out by the hon'ble first court in the said order dated March 22, 2005, as well as the impugned order passed by the said authorities.;