Limitation for income-tax assessment runs from completion of the assessment order, not later communication to the assessee.

Section 34(2) of the Indian Income-tax Act, 1922 was construed to govern the point when the Income-tax Officer completed the assessment and determined the tax payable, not the later communication of that order to the assessee. The statutory scheme treated assessment, determination of tax, and intimation under Section 29 as distinct steps, so service of the order was not part of completion for limitation purposes. On that reading, an assessment is "made" when the assessment order is completed, and the limitation challenge failed.

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Issues: Whether the assessment was made within the period of limitation prescribed under Section 34(2) of the Indian Income-tax Act, 1922.

Analysis: The limitation under Section 34(2) was held to govern the stage at which the Income-tax Officer completed the assessment and determined the tax payable, not the later communication of the order to the assessee. The statutory scheme under Section 23 showed that assessment, determination of tax, and subsequent intimation under Section 29 were distinct steps, and the requirement of communication was not part of the completion of assessment for limitation purposes. The expression "made" in Section 34(2) was therefore construed in the context of the Act as referring to the making of the assessment order by the officer, not its service or receipt by the assessee.

Conclusion: The assessment was made within time, and the question was answered in the affirmative against the assessee.

Final Conclusion: The limitation challenge failed, and the assessment was upheld as having been completed within the statutory period.

Ratio Decidendi: For purposes of Section 34(2) of the Indian Income-tax Act, 1922, an assessment is "made" when the Income-tax Officer completes the assessment order and determines the tax payable, not when the order is communicated to the assessee.

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