https://www.taxtmi.com/caselaws?id=6833 An order under section 23A of the Income-tax Act, 1922 is not an assessment order for the purpose of the four-year limitation in section 34(3). The provision was treated as a penal machinery meant to prevent tax evasion by controlling dividend distribution and imposing consequences for failure to distribute the statutory dividend. Because it does not itself assess income in the ordinary sense, proceedings under section 23A are not governed by the limitation applicable to assessment orders, and the bar of time does not apply. en-us Fri, 26 Nov 1965 00:00:00 +0530 Fri, 06 Feb 2009 15:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6833 An order under section 23A of the Income-tax Act, 1922 is not an assessment order for the purpose of the four-year limitation in section 34(3). The provision was treated as a penal machinery meant to prevent tax evasion by controlling dividend distribution and imposing consequences for failure to distribute the statutory dividend. Because it does not itself assess income in the ordinary sense, proceedings under section 23A are not governed by the limitation applicable to assessment orders, and the bar of time does not apply. Case-Laws Income Tax Fri, 26 Nov 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6833