https://www.taxtmi.com/caselaws?id=179524 A reassessment notice issued under Section 34(1)(a) of the Indian Income-tax Act, 1922, after expiry of the eight-year limitation period was not protected by the second proviso to Section 34(3). That proviso applies only where the reassessment is made in consequence of, or to give effect to, a finding or direction in an appellate order under Section 31, and the relevant finding must be necessary for disposal of the appeal for the year in question. An incidental observation that the income belonged to another assessment year was insufficient. The notice issued in 1963 for income assessable in 1944-45 was therefore barred by limitation. en-us Wed, 31 Mar 1965 00:00:00 +0530 Thu, 03 Mar 2016 15:54:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=179524 A reassessment notice issued under Section 34(1)(a) of the Indian Income-tax Act, 1922, after expiry of the eight-year limitation period was not protected by the second proviso to Section 34(3). That proviso applies only where the reassessment is made in consequence of, or to give effect to, a finding or direction in an appellate order under Section 31, and the relevant finding must be necessary for disposal of the appeal for the year in question. An incidental observation that the income belonged to another assessment year was insufficient. The notice issued in 1963 for income assessable in 1944-45 was therefore barred by limitation. Case-Laws Income Tax Wed, 31 Mar 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=179524