https://www.taxtmi.com/caselaws?id=5221 The transitional saving provision under the Income-tax Act, 1961 was applied on the basis of factual pendency of reassessment proceedings under Section 34 of the 1922 Act on the commencement date, not on whether those earlier proceedings were ultimately legally sustainable. Because proceedings relating to the same escaped income were already pending when the 1961 Act came into force, fresh reassessment by notice under Section 148 could not be initiated. The annulment of the earlier order did not render the pending proceedings non est for purposes of Section 297(2)(d)(ii), and the notice under the 1961 Act was held invalid. en-us Tue, 20 Nov 1979 00:00:00 +0530 Fri, 21 Nov 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5221 The transitional saving provision under the Income-tax Act, 1961 was applied on the basis of factual pendency of reassessment proceedings under Section 34 of the 1922 Act on the commencement date, not on whether those earlier proceedings were ultimately legally sustainable. Because proceedings relating to the same escaped income were already pending when the 1961 Act came into force, fresh reassessment by notice under Section 148 could not be initiated. The annulment of the earlier order did not render the pending proceedings non est for purposes of Section 297(2)(d)(ii), and the notice under the 1961 Act was held invalid. Case-Laws Income Tax Tue, 20 Nov 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5221