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    <title>1951 (1) TMI 38 - High Court Of Calcutta</title>
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    <description>Amounts actually received as interest in earlier years could not be brought into reassessment under section 34 of the Indian Income-tax Act once the statutory period had expired. The receipts in question had been received in 1922, 1928, 1929 and 1930, and their treatment by the assessee as lying in suspense, or as not yet taxable because litigation was pending, did not change their character as completed receipts. The revenue&#039;s reliance on authority concerning appropriation of open payments was inapposite, because these sums were not unappropriated payments on account but interest already received. Accordingly, the reassessment of Rs. 79,532 for assessment year 1939-40 was invalid.</description>
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    <pubDate>Tue, 02 Jan 1951 00:00:00 +0530</pubDate>
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      <title>1951 (1) TMI 38 - High Court Of Calcutta</title>
      <link>https://www.taxtmi.com/caselaws?id=193015</link>
      <description>Amounts actually received as interest in earlier years could not be brought into reassessment under section 34 of the Indian Income-tax Act once the statutory period had expired. The receipts in question had been received in 1922, 1928, 1929 and 1930, and their treatment by the assessee as lying in suspense, or as not yet taxable because litigation was pending, did not change their character as completed receipts. The revenue&#039;s reliance on authority concerning appropriation of open payments was inapposite, because these sums were not unappropriated payments on account but interest already received. Accordingly, the reassessment of Rs. 79,532 for assessment year 1939-40 was invalid.</description>
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      <pubDate>Tue, 02 Jan 1951 00:00:00 +0530</pubDate>
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