https://www.taxtmi.com/caselaws?id=6419 Reassessment under the Income-tax Act, 1922 was held to fall under the residual reopening provision, because the notices, sanction and assessment records showed no omission to file returns or failure to disclose material facts; the case therefore did not attract the clause for default in disclosure. The saving proviso to section 34(3) was construed as unavailable where the right to reopen had already become time-barred before the retrospective amendment, and it operated only for persons bound by or party to the earlier appellate proceedings. On that basis, the reassessments of the three assessees covered by appellate directions were sustained, while the reassessments of the others remained barred by limitation. en-us Thu, 16 Aug 1973 00:00:00 +0530 Fri, 05 Dec 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6419 Reassessment under the Income-tax Act, 1922 was held to fall under the residual reopening provision, because the notices, sanction and assessment records showed no omission to file returns or failure to disclose material facts; the case therefore did not attract the clause for default in disclosure. The saving proviso to section 34(3) was construed as unavailable where the right to reopen had already become time-barred before the retrospective amendment, and it operated only for persons bound by or party to the earlier appellate proceedings. On that basis, the reassessments of the three assessees covered by appellate directions were sustained, while the reassessments of the others remained barred by limitation. Case-Laws Income Tax Thu, 16 Aug 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6419