https://www.taxtmi.com/caselaws?id=128122 Section 171(6) of the Income-tax Act, 1961, which imposes joint and several personal liability on members of a Hindu undivided family where partition is discovered after assessment, was held to be substantive and prospective. It could not be applied to assessments already completed under the Income-tax Act, 1922, because it would create a new liability for past years. Section 297(2)(d)(ii) permitted reassessment of escaped income under the new Act, but only through the assessment machinery and not by importing fresh substantive liability. Accordingly, reopening under Sections 147 and 148 did not authorise recovery from individual members on the basis of Section 171(6). en-us Thu, 18 Dec 1975 00:00:00 +0530 Tue, 03 Jun 2025 17:24:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=128122 Section 171(6) of the Income-tax Act, 1961, which imposes joint and several personal liability on members of a Hindu undivided family where partition is discovered after assessment, was held to be substantive and prospective. It could not be applied to assessments already completed under the Income-tax Act, 1922, because it would create a new liability for past years. Section 297(2)(d)(ii) permitted reassessment of escaped income under the new Act, but only through the assessment machinery and not by importing fresh substantive liability. Accordingly, reopening under Sections 147 and 148 did not authorise recovery from individual members on the basis of Section 171(6). Case-Laws Income Tax Thu, 18 Dec 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=128122