https://www.taxtmi.com/caselaws?id=7490 An appellate direction can support reassessment only if it is necessary for disposing of the appeal, contains the requisite finding, and is made after hearing the affected person; otherwise, it cannot confer jurisdiction on the Income-tax Officer under section 147. On the stated facts, the direction in the firm's appeal did not find that the excluded income belonged to the partners, and the partners were not heard, so the section 153(3) deeming provision did not assist the revenue. Once that direction was invalid, the reassessment could not be treated as saved by the limitation exception and was therefore time-barred. en-us Tue, 12 Nov 1968 00:00:00 +0530 Fri, 20 Feb 2009 16:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7490 An appellate direction can support reassessment only if it is necessary for disposing of the appeal, contains the requisite finding, and is made after hearing the affected person; otherwise, it cannot confer jurisdiction on the Income-tax Officer under section 147. On the stated facts, the direction in the firm's appeal did not find that the excluded income belonged to the partners, and the partners were not heard, so the section 153(3) deeming provision did not assist the revenue. Once that direction was invalid, the reassessment could not be treated as saved by the limitation exception and was therefore time-barred. Case-Laws Income Tax Tue, 12 Nov 1968 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7490