https://www.taxtmi.com/caselaws?id=7769 Limitation under section 34(3) of the Indian Income-tax Act, 1922 governed original assessment and reassessment for escaped income, but did not restrict fresh assessment proceedings taken in consequence of appellate, revisional, or reference directions. The Bombay HC held that a fresh assessment made by the Income-tax Officer pursuant to such directions fell within the second proviso, which removed the limitation bar in those cases. It further held that the proviso was not discriminatory against an assessee who was a party to the earlier proceedings, and that the constitutional invalidity found in earlier Supreme Court rulings was confined to strangers to the assessment. The notices were therefore valid and the proviso was intra vires as applied to the petitioner. en-us Thu, 27 Feb 1969 00:00:00 +0530 Thu, 19 Mar 2009 09:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7769 Limitation under section 34(3) of the Indian Income-tax Act, 1922 governed original assessment and reassessment for escaped income, but did not restrict fresh assessment proceedings taken in consequence of appellate, revisional, or reference directions. The Bombay HC held that a fresh assessment made by the Income-tax Officer pursuant to such directions fell within the second proviso, which removed the limitation bar in those cases. It further held that the proviso was not discriminatory against an assessee who was a party to the earlier proceedings, and that the constitutional invalidity found in earlier Supreme Court rulings was confined to strangers to the assessment. The notices were therefore valid and the proviso was intra vires as applied to the petitioner. Case-Laws Income Tax Thu, 27 Feb 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7769