https://www.taxtmi.com/caselaws?id=7264 A return furnished voluntarily under section 22(3) of the Income-tax Act, 1922 could not be treated as a return under section 22(1) for invoking notice under section 22(4), because section 22(4) expressly applied only to returns under sub-sections (1) and (2) and omitted sub-section (3). The Court treated that omission as deliberate and refused to extend the machinery provision by implication, noting that the Act contained other provisions for enquiry and production of documents. Notice under section 22(4) was therefore invalid, and assessment under section 23(4) for non-compliance with that notice was unjustified; the appeal was dismissed in favour of the assessee. en-us Thu, 18 May 1967 00:00:00 +0530 Mon, 16 Feb 2009 12:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7264 A return furnished voluntarily under section 22(3) of the Income-tax Act, 1922 could not be treated as a return under section 22(1) for invoking notice under section 22(4), because section 22(4) expressly applied only to returns under sub-sections (1) and (2) and omitted sub-section (3). The Court treated that omission as deliberate and refused to extend the machinery provision by implication, noting that the Act contained other provisions for enquiry and production of documents. Notice under section 22(4) was therefore invalid, and assessment under section 23(4) for non-compliance with that notice was unjustified; the appeal was dismissed in favour of the assessee. Case-Laws Income Tax Thu, 18 May 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7264