https://www.taxtmi.com/caselaws?id=276684 Reassessment under section 34(1)(b) of the Income-tax Act, 1922 could not withdraw relief earlier allowed under section 23(3) for the Pakistan portion of dividend income where no certificate of assessment from Pakistan authorities was produced within the period under Article VI(b) of the Double Income-tax Avoidance Agreement. The Court held that the assessment records and demand notice showed no tax had been levied on that Pakistan income in the first place, and the statutory machinery did not support treating the matter as an assessment with deferred collection. Accordingly, the earlier relief could not be reversed on reassessment, and the question was answered in favour of the assessee. en-us Thu, 14 Apr 1960 00:00:00 +0530 Thu, 15 Nov 2018 18:17:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276684 Reassessment under section 34(1)(b) of the Income-tax Act, 1922 could not withdraw relief earlier allowed under section 23(3) for the Pakistan portion of dividend income where no certificate of assessment from Pakistan authorities was produced within the period under Article VI(b) of the Double Income-tax Avoidance Agreement. The Court held that the assessment records and demand notice showed no tax had been levied on that Pakistan income in the first place, and the statutory machinery did not support treating the matter as an assessment with deferred collection. Accordingly, the earlier relief could not be reversed on reassessment, and the question was answered in favour of the assessee. Case-Laws Income Tax Thu, 14 Apr 1960 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276684