Law:

Section:

Section 147 of the Income-tax Act, 1961 - Income escaping assessment - Non-disclosure of primary facts - Assessment year 1984-85 - Whether where Assessing Officer initiated reassessment proceedings on basis of definite information received from CBI about investments made by assessee and assessee had failed to disclose those investments in original return, validity of reassessment proceedings could not be questioned - Held, yes Section 147, read with section 143, of the Income-tax Act, 1961 - Income escaping assessment - General - Assessment year 1984-85 - Whether return filed in response to a notice under section 148 has to be treated as if it has been filed under section 139 and as such, procedural provisions for making an assessment under section 143(3) also come into play - Held, yes Section 69, read with section 260A, of the Income-tax Act, 1961 - Unexplained investments - Assessment year 1984-85 - Additions were made on account of unexplained investments - Tribunal found that despite repeated opportunities, assessee failed to lead any satisfactory evidence to explain source of such investments - Whether finding of Tribunal was purely a finding of fact involving no question of law much less a substantial question of law - Held, yes FACTS Subsequent to the completion of the assessment under section 143(3), the Assessing Officer received some information from the Central Bureau of Investigation and on the basis of such information, he issued a notice under section 148. Consequently, reassessment was made under section 147 whereby various additions were made under section 69. On appeal, the Commissioner (Appeals) rejected the assessee's challenge questioning the validity of reassessment. In respect of various additions, some were upheld while the others were remanded back for fresh adjudication by the Assessing Officer. On further appeal, the Tribunal upheld the findings of the Commissioner (Appeals). In the instant reference application, the assessee challenged the validity of reassessment proceedings on various grounds and also the additions made under section 69. HELD There was no merit in the assessee's contention that there was no CBI report and since…

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