Limitation in tax assessment cannot be bypassed without recorded concealment and supporting material within time.

Limitation for assessment cannot be extended by the concealment provisions unless concealment is actually found and supporting material is recorded within the statutory period. The note states that, on the facts discussed, no such finding or material existed within four years, so the concealment provision under the Income-tax Act could not be used to overcome the bar of time. The assessment was therefore treated as time-barred.

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Issues: Whether the assessment was barred by limitation and whether the case fell within the concealment provisions so as to permit action beyond the prescribed period.

Analysis: The Tribunal and the High Court found that no finding of concealment had been recorded and no material had been brought on record within the relevant four-year period to attract the concealment provision under section 271(1)(c) of the Income-tax Act, 1961, corresponding to section 28(1)(c) of the old Act. On the facts, the assessment was held to be beyond time.

Conclusion: The limitation objection succeeded and the assessment was held to be time-barred.

Ratio Decidendi: Where concealment is not found and no supporting material is recorded within the statutory period, the concealment provision cannot be invoked to defeat the bar of limitation.

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