https://www.taxtmi.com/caselaws?id=6306 Reassessment proceedings initiated under section 34(1)(a) of the Indian Income-tax Act, 1922 were treated as pending on the commencement of the Income-tax Act, 1961 for purposes of the saving clause. A proceeding does not cease to be pending merely because the initiating notice is later found to be time-barred or otherwise unable to yield relief; limitation affects the remedy, not the existence of the proceeding. As the earlier reassessment had been validly initiated by a competent authority and remained pending when the 1961 Act came into force, a fresh notice under section 148 could not be issued. en-us Tue, 07 Sep 1971 00:00:00 +0530 Thu, 04 Dec 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6306 Reassessment proceedings initiated under section 34(1)(a) of the Indian Income-tax Act, 1922 were treated as pending on the commencement of the Income-tax Act, 1961 for purposes of the saving clause. A proceeding does not cease to be pending merely because the initiating notice is later found to be time-barred or otherwise unable to yield relief; limitation affects the remedy, not the existence of the proceeding. As the earlier reassessment had been validly initiated by a competent authority and remained pending when the 1961 Act came into force, a fresh notice under section 148 could not be issued. Case-Laws Income Tax Tue, 07 Sep 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6306