https://www.taxtmi.com/caselaws?id=187976 The limitation-saving proviso to section 34(3) of the Income-tax Act, 1922 applies only where reassessment directly and necessarily follows a valid appellate finding or direction within jurisdiction. A reassessment notice for an earlier year was therefore not protected where the appellate order only found that the amount was not income of the later year, and any further observation about another year was outside the appellate authority's power. Because the notice was issued after limitation had expired and depended on independent factual questions, it was time-barred. The High Court also treated writ relief as available against a jurisdictionally invalid notice and quashed the reassessment proceedings under article 226. en-us Tue, 17 Mar 1959 00:00:00 +0530 Mon, 14 Nov 2016 17:28:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=187976 The limitation-saving proviso to section 34(3) of the Income-tax Act, 1922 applies only where reassessment directly and necessarily follows a valid appellate finding or direction within jurisdiction. A reassessment notice for an earlier year was therefore not protected where the appellate order only found that the amount was not income of the later year, and any further observation about another year was outside the appellate authority's power. Because the notice was issued after limitation had expired and depended on independent factual questions, it was time-barred. The High Court also treated writ relief as available against a jurisdictionally invalid notice and quashed the reassessment proceedings under article 226. Case-Laws Income Tax Tue, 17 Mar 1959 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=187976