https://www.taxtmi.com/caselaws?id=188863 Retrospective substitution of section 34 by the 1948 Amendment Act made the amended provision applicable to notices issued after the amendment's commencement date, so proceedings had to satisfy the substituted section. The proviso requiring recorded reasons and the Commissioner's satisfaction was a jurisdictional precondition, not a procedural formality, and non-compliance rendered the reassessment invalid. Filing a return in response to the notice did not waive objection, because compliance was compulsory and waiver could not cure absence of jurisdiction. The reassessment proceedings were therefore legally unsustainable. en-us Fri, 13 Jul 1956 00:00:00 +0530 Mon, 19 Dec 2016 10:57:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=188863 Retrospective substitution of section 34 by the 1948 Amendment Act made the amended provision applicable to notices issued after the amendment's commencement date, so proceedings had to satisfy the substituted section. The proviso requiring recorded reasons and the Commissioner's satisfaction was a jurisdictional precondition, not a procedural formality, and non-compliance rendered the reassessment invalid. Filing a return in response to the notice did not waive objection, because compliance was compulsory and waiver could not cure absence of jurisdiction. The reassessment proceedings were therefore legally unsustainable. Case-Laws Income Tax Fri, 13 Jul 1956 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=188863