https://www.taxtmi.com/caselaws?id=276286 The second proviso to section 34(3) of the Income-tax Act, 1922 was treated as a valid limitation-saving machinery for assessees who were actual parties to the earlier appellate proceedings, but not for third parties who were unrepresented. The reassessment dispute also turned on party status and limitation: the father, being bound by the appellate finding, could be reassessed in his individual capacity for all three years, while the son could not be bound as a third party for 1950-51 and 1951-52 because the notices were time-barred. Reassessment for 1952-53 was upheld for the son because the notice was within time. en-us Wed, 16 Sep 1964 00:00:00 +0530 Mon, 05 Nov 2018 11:50:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276286 The second proviso to section 34(3) of the Income-tax Act, 1922 was treated as a valid limitation-saving machinery for assessees who were actual parties to the earlier appellate proceedings, but not for third parties who were unrepresented. The reassessment dispute also turned on party status and limitation: the father, being bound by the appellate finding, could be reassessed in his individual capacity for all three years, while the son could not be bound as a third party for 1950-51 and 1951-52 because the notices were time-barred. Reassessment for 1952-53 was upheld for the son because the notice was within time. Case-Laws Income Tax Wed, 16 Sep 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276286