https://www.taxtmi.com/caselaws?id=7153 The second proviso to section 34(3) of the Indian Income-tax Act, 1922 was construed narrowly: limitation is saved only where the reassessment gives effect to a finding or direction necessary for disposing of the appeal or revision concerning the same assessment year. The words "in consequence of or to give effect to" do not widen that power to a different year. On that basis, reassessment for an assessment year outside the subject-matter of the earlier appellate or revisional proceedings was time-barred, and the question referred was answered against the revenue and in favour of the assessee. en-us Fri, 21 Jul 1967 00:00:00 +0530 Wed, 11 Feb 2009 18:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7153 The second proviso to section 34(3) of the Indian Income-tax Act, 1922 was construed narrowly: limitation is saved only where the reassessment gives effect to a finding or direction necessary for disposing of the appeal or revision concerning the same assessment year. The words "in consequence of or to give effect to" do not widen that power to a different year. On that basis, reassessment for an assessment year outside the subject-matter of the earlier appellate or revisional proceedings was time-barred, and the question referred was answered against the revenue and in favour of the assessee. Case-Laws Income Tax Fri, 21 Jul 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7153