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    <title>1964 (4) TMI 126 - BOMBAY HIGH COURT</title>
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    <description>Section 22(4) of the Income-tax Act, 1922, as amended in 1953, was treated as a procedural machinery provision governing assessment and not as one fixing substantive tax liability. The court held that the enlarged power to call for particulars applied to pending assessments, and the reference to operation from 1 April 1952 validated notices issued after that date even for earlier assessment years. The article 14 challenge failed because there is no vested right in procedure and the amended rule operated uniformly across pending matters. The notices were therefore valid and the constitutional objection was rejected.</description>
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    <pubDate>Wed, 15 Apr 1964 00:00:00 +0530</pubDate>
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      <title>1964 (4) TMI 126 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=191875</link>
      <description>Section 22(4) of the Income-tax Act, 1922, as amended in 1953, was treated as a procedural machinery provision governing assessment and not as one fixing substantive tax liability. The court held that the enlarged power to call for particulars applied to pending assessments, and the reference to operation from 1 April 1952 validated notices issued after that date even for earlier assessment years. The article 14 challenge failed because there is no vested right in procedure and the amended rule operated uniformly across pending matters. The notices were therefore valid and the constitutional objection was rejected.</description>
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      <pubDate>Wed, 15 Apr 1964 00:00:00 +0530</pubDate>
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