https://www.taxtmi.com/caselaws?id=276525 A notice under section 34(1)(a) of the Income-tax Act, 1922 is the jurisdictional foundation for reassessment and must be issued to the assessee whose income is sought to be reopened; a notice addressed only to an individual partner did not validly reopen the unregistered firm's assessment, so the reassessment and the penalties linked to that assessment year failed. By contrast, default under section 22(2) was established where the return was filed late, and the successor Income-tax Officer could decide the penalty proceedings on the existing written record without a fresh oral hearing, so the separate penalty for the later assessment year was sustained. en-us Tue, 25 Feb 1964 00:00:00 +0530 Tue, 13 Nov 2018 12:11:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276525 A notice under section 34(1)(a) of the Income-tax Act, 1922 is the jurisdictional foundation for reassessment and must be issued to the assessee whose income is sought to be reopened; a notice addressed only to an individual partner did not validly reopen the unregistered firm's assessment, so the reassessment and the penalties linked to that assessment year failed. By contrast, default under section 22(2) was established where the return was filed late, and the successor Income-tax Officer could decide the penalty proceedings on the existing written record without a fresh oral hearing, so the separate penalty for the later assessment year was sustained. Case-Laws Income Tax Tue, 25 Feb 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276525