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    <title>1953 (3) TMI 28 - CALCUTTA HIGH COURT</title>
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    <description>Notices under Section 34 of the Income-tax Act, 1922 were supported where the Income-tax Officer had a factual basis to believe that share-trading income had escaped assessment, and the High Court would not reappraise that satisfaction in writ jurisdiction. The amended Section 34, brought into force on 30 March 1948, applied by its own terms to assessment years still within the eight-year reopening period and validly authorised reassessment of earlier years covered by that limit. The amendment was treated as a procedural machinery provision, not a fresh tax charge, so it did not impair vested rights or require separate operation through the annual Finance Act. The reassessment notices were therefore upheld.</description>
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    <pubDate>Wed, 25 Mar 1953 00:00:00 +0530</pubDate>
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      <title>1953 (3) TMI 28 - CALCUTTA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=175921</link>
      <description>Notices under Section 34 of the Income-tax Act, 1922 were supported where the Income-tax Officer had a factual basis to believe that share-trading income had escaped assessment, and the High Court would not reappraise that satisfaction in writ jurisdiction. The amended Section 34, brought into force on 30 March 1948, applied by its own terms to assessment years still within the eight-year reopening period and validly authorised reassessment of earlier years covered by that limit. The amendment was treated as a procedural machinery provision, not a fresh tax charge, so it did not impair vested rights or require separate operation through the annual Finance Act. The reassessment notices were therefore upheld.</description>
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      <pubDate>Wed, 25 Mar 1953 00:00:00 +0530</pubDate>
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