https://www.taxtmi.com/caselaws?id=5653 Section 34 notices issued to give effect to appellate directions were not barred by limitation because the second proviso to section 34(3) applies where reassessment follows a finding or direction under section 31. The phrase "any person" in that proviso is not limited to complete strangers or only the illustrations in section 31(4); it covers a person directly and intimately connected with the assessment proceedings whose liability is affected by the appellate order. As the assessee-company had been directly involved in the original assessments, the appeal, and the directions to assess it, it could not claim stranger status. The limitation and Article 14 challenge therefore failed. en-us Tue, 17 Feb 1998 00:00:00 +0530 Thu, 27 Nov 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5653 Section 34 notices issued to give effect to appellate directions were not barred by limitation because the second proviso to section 34(3) applies where reassessment follows a finding or direction under section 31. The phrase "any person" in that proviso is not limited to complete strangers or only the illustrations in section 31(4); it covers a person directly and intimately connected with the assessment proceedings whose liability is affected by the appellate order. As the assessee-company had been directly involved in the original assessments, the appeal, and the directions to assess it, it could not claim stranger status. The limitation and Article 14 challenge therefore failed. Case-Laws Income Tax Tue, 17 Feb 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5653