https://www.taxtmi.com/caselaws?id=7405 Income can be treated as having escaped assessment where returned income is not brought to tax within the period allowed, even if the omission is due to limitation rather than nondisclosure; the court treated this as falling within escaped assessment and upheld that issue for the Revenue. Reassessment under the second proviso to section 34(3) is available only when it is truly in consequence of, or to give effect to, an appellate finding or direction and only against a person directly and immediately connected with the assessment under appeal; that requirement was absent here, so the proviso could not sustain reopening. The reassessment notices were therefore time-barred and unsustainable. en-us Wed, 07 Aug 1968 00:00:00 +0530 Thu, 19 Feb 2009 11:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7405 Income can be treated as having escaped assessment where returned income is not brought to tax within the period allowed, even if the omission is due to limitation rather than nondisclosure; the court treated this as falling within escaped assessment and upheld that issue for the Revenue. Reassessment under the second proviso to section 34(3) is available only when it is truly in consequence of, or to give effect to, an appellate finding or direction and only against a person directly and immediately connected with the assessment under appeal; that requirement was absent here, so the proviso could not sustain reopening. The reassessment notices were therefore time-barred and unsustainable. Case-Laws Income Tax Wed, 07 Aug 1968 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7405