Finality in income-tax assessments prevails where the Revenue long treated taxpayers as individuals and collected tax accordingly.

Finality and fairness prevented disturbance of a long-settled income-tax assessment where the Revenue had already assessed the concerned person, informed the assessing officer, and the Tribunal reasonably treated that assessment as final. The Court also declined to interfere with the Tribunal's setting aside of the assessment on an association of persons because more than three decades had passed, the taxpayers had been treated as individuals, tax had been collected on that basis, and no refund had been made. The order setting aside the impugned assessments was therefore upheld against the Revenue.

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Issues: (i) Whether the assessment made on the other person had become final. (ii) Whether the Tribunal was justified in setting aside the assessment made on the association of persons and in declining to disturb the Tribunal's order in view of the long passage of time and prior assessment of the individuals as such.

Issue (i): Whether the assessment made on the other person had become final.

Analysis: The record showed that the person concerned had already been assessed by the relevant Income-tax Officer and that intimation of such assessment had been sent to the assessing officer who later made the impugned assessment. That factual position was not disputed, and the Tribunal's view that the assessment had attained finality was held to be justified and reasonable.

Conclusion: The issue was answered against the Revenue.

Issue (ii): Whether the Tribunal was justified in setting aside the assessment made on the association of persons and in declining to disturb the Tribunal's order in view of the long passage of time and prior assessment of the individuals as such.

Analysis: Although the Revenue may normally tax the correct person, the Court declined to interfere because more than three decades had elapsed since the assessment year, the assessees had been treated as individuals on the Revenue's own approach, tax had already been collected on that basis, and the amount collected had not been refunded. In those circumstances, disturbing the Tribunal's order was considered unwarranted.

Conclusion: The issue was answered in favour of the assessee and against the Revenue.

Final Conclusion: The reference was decided against the Revenue, and the Tribunal's order setting aside the impugned assessments was upheld.

Ratio Decidendi: Where the Revenue has long treated the taxpayers as individuals, collected tax accordingly, and allowed the matter to remain settled for decades, the assessment will not be disturbed merely to tax a different person at a much later stage; finality and fairness may prevail over a belated attempt to reach the correct taxable entity.

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