Where person has dual capacity, notice u/s. 148 must specify particular capacity

HIGH COURT OF ALLAHABAD Gokul Chand Versus Income-tax Officer A.P. MISRA AND M.C. AGARWAL, JJ. CIVIL MISC. WRIT PETITION NO. 223 OF 1980 JULY 25, 1994 ORDER Agarwal, J. These two petitions under article 226 of the Constitution of India have been filed challenging the issue of notices under section 148 of the Income-tax Act, 1961 (‘the Act’) for the assessment years 1971-72 and 1975-76, whereby the ITO, Gonda, required the petitioner to file returns of income for these years as he had reason to believe that the petitioner’s income for these years had escape...