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    <title>1971 (9) TMI 22 - Supreme Court</title>
    <link>https://www.taxtmi.com/caselaws?id=6334</link>
    <description>Reassessment notices issued under section 148 of the Income-tax Act, 1961 were treated as invalid where reassessment proceedings had already been commenced and were pending under section 34(1)(b) of the Indian Income-tax Act, 1922. The later Act could not be used to initiate a fresh notice-based proceeding in that situation, and section 150(1) did not apply because the relied-on finding or direction must arise from an order under the 1961 Act, not the earlier enactment. The proviso to section 34 of the 1922 Act also could not assist the Revenue, as no proceeding had been initiated under it. The notices were therefore quashed.</description>
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    <pubDate>Tue, 07 Sep 1971 00:00:00 +0530</pubDate>
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      <title>1971 (9) TMI 22 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=6334</link>
      <description>Reassessment notices issued under section 148 of the Income-tax Act, 1961 were treated as invalid where reassessment proceedings had already been commenced and were pending under section 34(1)(b) of the Indian Income-tax Act, 1922. The later Act could not be used to initiate a fresh notice-based proceeding in that situation, and section 150(1) did not apply because the relied-on finding or direction must arise from an order under the 1961 Act, not the earlier enactment. The proviso to section 34 of the 1922 Act also could not assist the Revenue, as no proceeding had been initiated under it. The notices were therefore quashed.</description>
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      <pubDate>Tue, 07 Sep 1971 00:00:00 +0530</pubDate>
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