https://www.taxtmi.com/caselaws?id=186015 A return filed after the statutory four-year period is outside the protection of section 22(3) and cannot be treated as a valid return to bar reassessment under section 34. By contrast, a return filed before expiry of that period and before assessment is a valid return that prevents later resort to section 34, with any penalty based on an unauthorised reassessment not surviving. For penalty and recovery proceedings under section 46(1) and the proviso to section 45, liability follows valid demand and non-compliance unless the assessee establishes facts bringing the case within the proviso; those issues were treated as evidentiary rather than jurisdictional. en-us Mon, 16 Apr 1962 00:00:00 +0530 Mon, 05 Sep 2016 17:20:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=186015 A return filed after the statutory four-year period is outside the protection of section 22(3) and cannot be treated as a valid return to bar reassessment under section 34. By contrast, a return filed before expiry of that period and before assessment is a valid return that prevents later resort to section 34, with any penalty based on an unauthorised reassessment not surviving. For penalty and recovery proceedings under section 46(1) and the proviso to section 45, liability follows valid demand and non-compliance unless the assessee establishes facts bringing the case within the proviso; those issues were treated as evidentiary rather than jurisdictional. Case-Laws Income Tax Mon, 16 Apr 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=186015