Supreme Court of India
Commissioner of Income-tax, Gujarat v. A. Raman & Company
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From the headnote
Indian Income-tax Act, 1961. s. 147-Conditions for the exercise of power to re-open assessnient. Constitution of India. 1950. Art. 226-Powers of High Court to issue writ when Income-tax Officer's jurisdiction to issue notice under s. 147 of the Indian Income-tax Act, 1961 is questioned-High Court must not re~ppraise evidence. The assessee firm consisted of two partners who were managers of their respective Hindu Undivided Families. The firm sold its goods to the aforesaid families· and the families again sold the goods on their own account. In income-tax proceedings for the years 195\1- 60,
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