https://www.taxtmi.com/caselaws?id=189911 A notice under section 34 addressed to the assessee without expressly stating that it was issued to him as principal officer of an association of individuals was valid where the earlier assessment had already made the relevant capacity clear; the omission did not invalidate the notice. However, reassessment and appellate proceedings had to stay within the same assessed person and representative capacity, and the Income-tax Officer, Appellate Assistant Commissioner, and Tribunal could not substitute an entirely different association of individuals for the one originally assessed. On that basis, fiscal authorities could not create a fresh assessment against a new group at the appellate stage; the proper course was a fresh assessment if the composition had changed. en-us Wed, 17 Nov 1954 00:00:00 +0530 Wed, 25 Jan 2017 15:43:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189911 A notice under section 34 addressed to the assessee without expressly stating that it was issued to him as principal officer of an association of individuals was valid where the earlier assessment had already made the relevant capacity clear; the omission did not invalidate the notice. However, reassessment and appellate proceedings had to stay within the same assessed person and representative capacity, and the Income-tax Officer, Appellate Assistant Commissioner, and Tribunal could not substitute an entirely different association of individuals for the one originally assessed. On that basis, fiscal authorities could not create a fresh assessment against a new group at the appellate stage; the proper course was a fresh assessment if the composition had changed. Case-Laws Income Tax Wed, 17 Nov 1954 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189911