https://www.taxtmi.com/caselaws?id=177286 The High Court found the assessment under section 34(1)(a) of the Indian Income-tax Act, 1922 invalid due to the lack of conclusive determination on the ownership of the disputed income. Emphasizing the necessity for clear factual findings, the court ruled in favor of the assessee, highlighting the requirement for a genuine "reason to believe" for initiating assessments. The court directed the department to pay the costs of the reference, underscoring the importance of definitive Tribunal findings in such cases. en-us Fri, 14 Oct 1966 00:00:00 +0530 Wed, 06 Jan 2016 16:12:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=177286 The High Court found the assessment under section 34(1)(a) of the Indian Income-tax Act, 1922 invalid due to the lack of conclusive determination on the ownership of the disputed income. Emphasizing the necessity for clear factual findings, the court ruled in favor of the assessee, highlighting the requirement for a genuine "reason to believe" for initiating assessments. The court directed the department to pay the costs of the reference, underscoring the importance of definitive Tribunal findings in such cases. Case-Laws Income Tax Fri, 14 Oct 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=177286