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    <title>1964 (12) TMI 3 - CALCUTTA High Court</title>
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    <description>Section 297(2)(a) of the Income-tax Act, 1961 was construed broadly to preserve the old law for pending assessment machinery under the repealed 1922 Act, including revisionary proceedings under section 33B. The Court treated revision as part of the assessment process because it could lead to enhancement, modification, cancellation, or fresh assessment, so the Commissioner&#039;s initiation of revision for a pre-commencement return was valid. Clause (4) of the Income-tax (Removal of Difficulties) Order, 1962 was also upheld because it was consistent with the saving scheme in section 297 and merely clarified that appeal, reference, and revision under the repealed Act could continue.</description>
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    <pubDate>Tue, 08 Dec 1964 00:00:00 +0530</pubDate>
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      <title>1964 (12) TMI 3 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=6676</link>
      <description>Section 297(2)(a) of the Income-tax Act, 1961 was construed broadly to preserve the old law for pending assessment machinery under the repealed 1922 Act, including revisionary proceedings under section 33B. The Court treated revision as part of the assessment process because it could lead to enhancement, modification, cancellation, or fresh assessment, so the Commissioner&#039;s initiation of revision for a pre-commencement return was valid. Clause (4) of the Income-tax (Removal of Difficulties) Order, 1962 was also upheld because it was consistent with the saving scheme in section 297 and merely clarified that appeal, reference, and revision under the repealed Act could continue.</description>
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      <pubDate>Tue, 08 Dec 1964 00:00:00 +0530</pubDate>
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