https://www.taxtmi.com/caselaws?id=193019 A reassessment proceeding under the Income-tax Act, 1922 commences only on valid service of notice; mere issue of a notice does not create pending proceedings. On that basis, no proceeding was pending at the commencement of the Income-tax Act, 1961. A saving provision in a repealing statute preserves only subsisting rights and valid pending proceedings, and does not revive a reassessment remedy already barred under the repealed law. Accordingly, section 297(2)(d)(ii) did not authorise a fresh notice under section 148, and the reopening was held without jurisdiction. en-us Tue, 15 Dec 1964 00:00:00 +0530 Sat, 08 Jul 2017 17:08:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=193019 A reassessment proceeding under the Income-tax Act, 1922 commences only on valid service of notice; mere issue of a notice does not create pending proceedings. On that basis, no proceeding was pending at the commencement of the Income-tax Act, 1961. A saving provision in a repealing statute preserves only subsisting rights and valid pending proceedings, and does not revive a reassessment remedy already barred under the repealed law. Accordingly, section 297(2)(d)(ii) did not authorise a fresh notice under section 148, and the reopening was held without jurisdiction. Case-Laws Income Tax Tue, 15 Dec 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=193019