https://www.taxtmi.com/caselaws?id=6940 A reassessment notice under section 34(1)(b) could not be founded on deemed dividend income until an order under section 23A(1) was actually made against the company, because the statutory fiction bringing such income into existence arose only on that order. Before then, no income existed in the shareholder's hands in law or fact, so the Income-tax Officer could not validly form the belief that income had escaped assessment. Strict compliance with section 34(1)(b) was therefore required, and mere initiation of section 23A(1) proceedings was insufficient. en-us Thu, 27 Apr 1967 00:00:00 +0530 Sat, 07 Feb 2009 11:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6940 A reassessment notice under section 34(1)(b) could not be founded on deemed dividend income until an order under section 23A(1) was actually made against the company, because the statutory fiction bringing such income into existence arose only on that order. Before then, no income existed in the shareholder's hands in law or fact, so the Income-tax Officer could not validly form the belief that income had escaped assessment. Strict compliance with section 34(1)(b) was therefore required, and mere initiation of section 23A(1) proceedings was insufficient. Case-Laws Income Tax Thu, 27 Apr 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6940