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    <title>1967 (7) TMI 56 - ALLAHABAD High Court</title>
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    <description>A finding recorded in proceedings for one assessment year cannot, by itself, be treated as a finding or direction under the second proviso to section 34(3) so as to justify reassessment of a different assessment year; the assessee succeeded on this point. Reassessment initiated under section 34(1)(b) remained governed by the limitation in section 34(3), and where notice was served after four years from the end of the relevant assessment year, the proceedings were time-barred; the assessee succeeded on limitation as well. The reassessment for the earlier year could not be sustained because the statutory bar on limitation was not displaced by the earlier year&#039;s finding.</description>
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    <pubDate>Tue, 04 Jul 1967 00:00:00 +0530</pubDate>
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      <title>1967 (7) TMI 56 - ALLAHABAD High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=7259</link>
      <description>A finding recorded in proceedings for one assessment year cannot, by itself, be treated as a finding or direction under the second proviso to section 34(3) so as to justify reassessment of a different assessment year; the assessee succeeded on this point. Reassessment initiated under section 34(1)(b) remained governed by the limitation in section 34(3), and where notice was served after four years from the end of the relevant assessment year, the proceedings were time-barred; the assessee succeeded on limitation as well. The reassessment for the earlier year could not be sustained because the statutory bar on limitation was not displaced by the earlier year&#039;s finding.</description>
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      <pubDate>Tue, 04 Jul 1967 00:00:00 +0530</pubDate>
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