https://www.taxtmi.com/caselaws?id=191879 Reassessment of a shareholder under section 34 was time-barred because limitation had to be computed by reference to the shareholder's assessment year, not the date of the company's section 23A order. A notice issued after expiry of that period could not be validated by an Appellate Assistant Commissioner's direction where the direction rested on an erroneous legal basis and sought to confer jurisdiction that had not been lawfully acquired. The saving proviso to section 34(3) applies only to a lawful direction within appellate powers. The reassessment was therefore invalid and barred by limitation. en-us Mon, 13 Aug 1962 00:00:00 +0530 Sat, 29 Apr 2017 17:47:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=191879 Reassessment of a shareholder under section 34 was time-barred because limitation had to be computed by reference to the shareholder's assessment year, not the date of the company's section 23A order. A notice issued after expiry of that period could not be validated by an Appellate Assistant Commissioner's direction where the direction rested on an erroneous legal basis and sought to confer jurisdiction that had not been lawfully acquired. The saving proviso to section 34(3) applies only to a lawful direction within appellate powers. The reassessment was therefore invalid and barred by limitation. Case-Laws Income Tax Mon, 13 Aug 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=191879