https://www.taxtmi.com/caselaws?id=276864 A notice under section 34 was challenged as time-barred because it was issued after the ordinary limitation period. The 1953 proviso to section 34(3) was treated as incapable of reviving a reopening right that had already become barred, absent clear retrospective language, and the proviso relating to action taken in consequence of a finding or direction was held not clearly applicable on the facts. By contrast, section 34(4), inserted by the 1959 amendment, was construed as giving retrospective power to issue notices even where the earlier right had expired, consistently with the amended limitation scheme in section 34(1). The notice was therefore held valid. en-us Tue, 05 Dec 1961 00:00:00 +0530 Mon, 19 Nov 2018 16:50:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276864 A notice under section 34 was challenged as time-barred because it was issued after the ordinary limitation period. The 1953 proviso to section 34(3) was treated as incapable of reviving a reopening right that had already become barred, absent clear retrospective language, and the proviso relating to action taken in consequence of a finding or direction was held not clearly applicable on the facts. By contrast, section 34(4), inserted by the 1959 amendment, was construed as giving retrospective power to issue notices even where the earlier right had expired, consistently with the amended limitation scheme in section 34(1). The notice was therefore held valid. Case-Laws Income Tax Tue, 05 Dec 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276864