https://www.taxtmi.com/caselaws?id=6909 A reassessment notice issued after expiry of the normal limitation period under section 34(3) was held time-barred because the only possible saving provision could not be invoked on the basis of an appellate observation made without jurisdiction. The appellate authority's direction to reopen the assessment year 1952-53 went beyond the scope of its powers for limitation purposes, and a finding or direction under the second proviso must be confined to matters lawfully arising in the relevant appellate proceeding and assessment year. As a result, the deemed dividend could not validly be included in the assessee's assessment for 1952-53. en-us Thu, 13 Jan 1966 00:00:00 +0530 Sat, 07 Feb 2009 08:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6909 A reassessment notice issued after expiry of the normal limitation period under section 34(3) was held time-barred because the only possible saving provision could not be invoked on the basis of an appellate observation made without jurisdiction. The appellate authority's direction to reopen the assessment year 1952-53 went beyond the scope of its powers for limitation purposes, and a finding or direction under the second proviso must be confined to matters lawfully arising in the relevant appellate proceeding and assessment year. As a result, the deemed dividend could not validly be included in the assessee's assessment for 1952-53. Case-Laws Income Tax Thu, 13 Jan 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6909