https://www.taxtmi.com/caselaws?id=7283 Reassessment under the 1922 Income-tax Act depended on the Department proving that the notices were issued under the precise statutory clause attracting the limitation-saving provision. On the record, the authorities had proceeded generally under section 34 without establishing clause (a), so section 4 of the 1959 Amendment Act did not support the 1944-45 reassessments, which were also barred because the assessees had disclosed their returns and the four-year limit had already expired before the amended proviso operated. For Onkarmal Meghraj, the 1943-44 reopening was already time-barred before the retrospective amendment took effect. en-us Mon, 29 Jan 1968 00:00:00 +0530 Mon, 16 Feb 2009 18:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7283 Reassessment under the 1922 Income-tax Act depended on the Department proving that the notices were issued under the precise statutory clause attracting the limitation-saving provision. On the record, the authorities had proceeded generally under section 34 without establishing clause (a), so section 4 of the 1959 Amendment Act did not support the 1944-45 reassessments, which were also barred because the assessees had disclosed their returns and the four-year limit had already expired before the amended proviso operated. For Onkarmal Meghraj, the 1943-44 reopening was already time-barred before the retrospective amendment took effect. Case-Laws Income Tax Mon, 29 Jan 1968 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7283