Section 147
Income escaping assessment
Piecemeal
assessments to be avoided - ITOs should not make
any piecemeal assessments or make any observations in the course of assessment
proceedings that some assessable income, the existence of which is in their knowledge,
will be subject to assessment subsequently under section 147. In particular,
the assessment of a partner of a firm should not be made without including the
share income, or an observation made that it would be included later on.—Circular : F. No. 45A/180/52-IT, dated 6-12-1955.