COMMISSIONER OF INCOME TAX (EXEMPTIONS) vs. M/S. ROLAND EDUCATIONAL AND CHARITABLE TRUST

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE MURAHARI SRI RAMAN

2. The principal question which stands posited for our consideration is whether the Assessing Officer3 was justified in invoking Section 148 of the Income Tax Act, 19614 basis the report which had been received from the Investigation Wing. The assessee appears to have principally asserted that this was clearly a case of “borrowed satisfaction” since full and true disclosures