https://www.taxtmi.com/caselaws?id=6251 For the first proviso to section 34(3) of the Indian Income-tax Act, 1922, "assessment" meant more than computation of total income: it was complete only when the tax payable was also determined. Although section 23 distinguishes between computation of income and determination of tax, the Court read section 34(3) in its own context and accepted the settled construction previously followed by the revenue and the Madras High Court. The Court declined to depart from that interpretation, noting that the corresponding provisions of the 1961 Act were materially different. On that basis, the limitation issue was decided in favour of the assessee. en-us Wed, 28 Jul 1971 00:00:00 +0530 Wed, 03 Dec 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6251 For the first proviso to section 34(3) of the Indian Income-tax Act, 1922, "assessment" meant more than computation of total income: it was complete only when the tax payable was also determined. Although section 23 distinguishes between computation of income and determination of tax, the Court read section 34(3) in its own context and accepted the settled construction previously followed by the revenue and the Madras High Court. The Court declined to depart from that interpretation, noting that the corresponding provisions of the 1961 Act were materially different. On that basis, the limitation issue was decided in favour of the assessee. Case-Laws Income Tax Wed, 28 Jul 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6251