Reassessment notice limitation runs from the previous year's end, and no express non-disclosure recital was required.

Limitation for reopening under section 34(1)(a) runs from the end of the previous year for which the return is required under section 22, not from the assessment year, so a notice issued after eight years from that end date is barred. The notice also need not expressly recite that the assessee failed to disclose fully and truly all material facts, because section 34 read with section 22(2) does not require that statement. The reassessment challenge therefore succeeded on limitation, and the notice and proceedings were quashed, while the objection to the notice's wording failed.

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Issues: (i) Whether the period of eight years for issue of notice under section 34(1)(a) runs from the end of the previous year or the assessment year; (ii) whether the notice under section 34 must specifically state that the assessee failed to disclose fully and truly all material facts necessary for assessment.

Issue (i): Whether the period of eight years for issue of notice under section 34(1)(a) runs from the end of the previous year or the assessment year.

Analysis: The language of section 34(1)(a), read with section 22, shows that the return contemplated is the return of income for the previous year. The expression "any year" in clause (a) was construed to mean the previous year, and the later reference to "that year" carries the same meaning. The computation of limitation therefore begins from the end of the year for which the return is to be furnished, not from the assessment year. The amendment in 1956 did not alter this position.

Conclusion: The notice had to be issued within eight years from the end of the previous year, and the notice issued after that period was barred by limitation.

Issue (ii): Whether the notice under section 34 must specifically state that the assessee failed to disclose fully and truly all material facts necessary for assessment.

Analysis: Section 34 only requires a notice containing the requirements permissible under section 22(2). Section 22(2) does not require the notice to recite that the assessee failed to make a full and true disclosure of material facts. No additional statement of that kind was necessary in the notice.

Conclusion: The objection to the notice on this ground failed.

Final Conclusion: The challenge to the reassessment notice succeeded on the limitation issue, and the notice and all proceedings taken pursuant to it were quashed, while the contention regarding the contents of the notice was rejected.

Ratio Decidendi: For notices under section 34(1)(a), limitation runs from the end of the previous year for which the return is required under section 22, and the notice need not expressly state non-disclosure of material facts if the statute does not require such recitation.

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