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    <title>1953 (3) TMI 26 - BOMBAY HIGH COURT</title>
    <link>https://www.taxtmi.com/caselaws?id=174237</link>
    <description>Successor liability under the unamended Section 26(2) of the Income-tax Act, 1922 attached where the successor was carrying on the business when assessment proceedings were initiated and continued, because &quot;at the time of making an assessment&quot; was construed to cover the entire assessment process from notice to completion. The deeming words treating the successor as having carried on the business throughout the previous year and received its profits were treated as controlling. An amendment to Section 26(2) did not displace the unamended provision where notice commencing proceedings had already been issued. The asserted sufficient cause for non-compliance with notice under Section 22(4) failed because it was only a challenge to liability, so the best judgment assessment was upheld.</description>
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    <pubDate>Fri, 13 Mar 1953 00:00:00 +0530</pubDate>
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      <title>1953 (3) TMI 26 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=174237</link>
      <description>Successor liability under the unamended Section 26(2) of the Income-tax Act, 1922 attached where the successor was carrying on the business when assessment proceedings were initiated and continued, because &quot;at the time of making an assessment&quot; was construed to cover the entire assessment process from notice to completion. The deeming words treating the successor as having carried on the business throughout the previous year and received its profits were treated as controlling. An amendment to Section 26(2) did not displace the unamended provision where notice commencing proceedings had already been issued. The asserted sufficient cause for non-compliance with notice under Section 22(4) failed because it was only a challenge to liability, so the best judgment assessment was upheld.</description>
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      <pubDate>Fri, 13 Mar 1953 00:00:00 +0530</pubDate>
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