https://www.taxtmi.com/caselaws?id=20506 Suo motu revisional proceedings under section 34 were assessed against the temporal limits and purpose of statutory revision/rectification provisions, with the court applying the Limitation Principle that normally the outer limit for initiating suo motu revision aligns with the periods contemplated for reopening. Reopening beyond those periods requires cogent, demonstrable supervening events or exceptional difficulties and a bona fide, reasonable exercise of power. Absent material showing such exceptional circumstances, the long lapse rendered the revisional exercise unreasonable; the proceedings dated March 30, 1991, in respect of the earlier assessments were therefore vitiated and set aside in favour of the assessees. en-us Thu, 18 Feb 1993 00:00:00 +0530 Sat, 14 Nov 2009 13:23:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=20506 Suo motu revisional proceedings under section 34 were assessed against the temporal limits and purpose of statutory revision/rectification provisions, with the court applying the Limitation Principle that normally the outer limit for initiating suo motu revision aligns with the periods contemplated for reopening. Reopening beyond those periods requires cogent, demonstrable supervening events or exceptional difficulties and a bona fide, reasonable exercise of power. Absent material showing such exceptional circumstances, the long lapse rendered the revisional exercise unreasonable; the proceedings dated March 30, 1991, in respect of the earlier assessments were therefore vitiated and set aside in favour of the assessees. Case-Laws Income Tax Thu, 18 Feb 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=20506