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    <title>1969 (9) TMI 11 - ALLAHABAD High Court</title>
    <link>https://www.taxtmi.com/caselaws?id=7647</link>
    <description>Assessment orders for an earlier assessment year were held time-barred because the limitation under the 1922 Act had already expired before the 1961 Act came into force, and a later assessment could not be saved by section 153(1)(c) since that provision required a valid return under section 139(4) or section 139(5). A voluntary return filed after the statutory period could not extend the time for assessment or validate the barred proceedings. The assessee was also not precluded by compromise or by filing such a return from challenging limitation in writ jurisdiction, as there was no clear and express waiver of that objection. The demand notices therefore could not stand.</description>
    <language>en-us</language>
    <pubDate>Tue, 02 Sep 1969 00:00:00 +0530</pubDate>
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      <title>1969 (9) TMI 11 - ALLAHABAD High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=7647</link>
      <description>Assessment orders for an earlier assessment year were held time-barred because the limitation under the 1922 Act had already expired before the 1961 Act came into force, and a later assessment could not be saved by section 153(1)(c) since that provision required a valid return under section 139(4) or section 139(5). A voluntary return filed after the statutory period could not extend the time for assessment or validate the barred proceedings. The assessee was also not precluded by compromise or by filing such a return from challenging limitation in writ jurisdiction, as there was no clear and express waiver of that objection. The demand notices therefore could not stand.</description>
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      <pubDate>Tue, 02 Sep 1969 00:00:00 +0530</pubDate>
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