https://www.taxtmi.com/caselaws?id=8014 For the second proviso to section 34(3), a prior observation counts as a qualifying finding only if it was necessary to dispose of the earlier appeal or reference for the relevant assessment year; an incidental remark does not extend limitation, so the observation that income belonged to the trust was insufficient. The proviso also applies only where the person sought to be reassessed is intimately connected with the earlier assessment in a legally relevant sense; a trust is a separate legal entity and was treated as a stranger to the settlor's individual assessment, so it was not "any person" within the proviso. On both grounds, the reassessment remained time-barred. en-us Wed, 18 Mar 1970 00:00:00 +0530 Fri, 27 Mar 2009 11:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8014 For the second proviso to section 34(3), a prior observation counts as a qualifying finding only if it was necessary to dispose of the earlier appeal or reference for the relevant assessment year; an incidental remark does not extend limitation, so the observation that income belonged to the trust was insufficient. The proviso also applies only where the person sought to be reassessed is intimately connected with the earlier assessment in a legally relevant sense; a trust is a separate legal entity and was treated as a stranger to the settlor's individual assessment, so it was not "any person" within the proviso. On both grounds, the reassessment remained time-barred. Case-Laws Income Tax Wed, 18 Mar 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8014