https://www.taxtmi.com/caselaws?id=6910 A reassessment notice issued under section 34 of the Income-tax Act, 1922 for assessment year 1952-53 was treated as time-barred because it was issued after the four-year limitation period. The department invoked the second proviso to section 34(3) on the basis of an appellate finding about deemed dividend income, but the controlling principle was that such a finding can extend limitation only if it relates to the very assessment year under reassessment. An observation concerning another year cannot save proceedings for a different year. On that basis, the notice and consequent reassessment were held invalid. en-us Thu, 13 Jan 1966 00:00:00 +0530 Sat, 07 Feb 2009 08:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6910 A reassessment notice issued under section 34 of the Income-tax Act, 1922 for assessment year 1952-53 was treated as time-barred because it was issued after the four-year limitation period. The department invoked the second proviso to section 34(3) on the basis of an appellate finding about deemed dividend income, but the controlling principle was that such a finding can extend limitation only if it relates to the very assessment year under reassessment. An observation concerning another year cannot save proceedings for a different year. On that basis, the notice and consequent reassessment were held invalid. Case-Laws Income Tax Thu, 13 Jan 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6910