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    <title>1966 (10) TMI 157 - Allahabad high court</title>
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    <description>The Appellate Assistant Commissioner&#039;s powers under sections 31(3) and 31(4) of the Income-tax Act, 1922 were limited to orders that were consequential to the appeal before him. A direction that a deleted cash credit be assessed in the individual hands of the partners was held to be a substantive attempt to reopen a different assessee&#039;s liability, not a permissible consequential amendment. The second proviso to section 34(3) could apply only where the finding or direction was within jurisdiction and necessary to the appeal decided. Accordingly, the attempted reliance on that proviso to save a time-barred reassessment was impermissible.</description>
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    <pubDate>Thu, 06 Oct 1966 00:00:00 +0530</pubDate>
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      <title>1966 (10) TMI 157 - Allahabad high court</title>
      <link>https://www.taxtmi.com/caselaws?id=191357</link>
      <description>The Appellate Assistant Commissioner&#039;s powers under sections 31(3) and 31(4) of the Income-tax Act, 1922 were limited to orders that were consequential to the appeal before him. A direction that a deleted cash credit be assessed in the individual hands of the partners was held to be a substantive attempt to reopen a different assessee&#039;s liability, not a permissible consequential amendment. The second proviso to section 34(3) could apply only where the finding or direction was within jurisdiction and necessary to the appeal decided. Accordingly, the attempted reliance on that proviso to save a time-barred reassessment was impermissible.</description>
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      <pubDate>Thu, 06 Oct 1966 00:00:00 +0530</pubDate>
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