https://www.taxtmi.com/caselaws?id=296593 Section 171(6) of the Income-tax Act, 1961 was treated as creating a new substantive liability by making former members of a Hindu undivided family jointly and severally liable for tax after partition. That liability could not be applied retrospectively to assessments completed under the Income-tax Act, 1922, because no clear language required such construction. Section 297(2)(d) was confined to the machinery for reassessment of escaped income and did not carry forward a substantive liability-creating provision like Section 171(6). The result was that pre-1962 assessments could not be enforced personally against the HUF members under the new Act. en-us Thu, 18 Dec 1975 00:00:00 +0530 Thu, 29 Jul 2021 15:23:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296593 Section 171(6) of the Income-tax Act, 1961 was treated as creating a new substantive liability by making former members of a Hindu undivided family jointly and severally liable for tax after partition. That liability could not be applied retrospectively to assessments completed under the Income-tax Act, 1922, because no clear language required such construction. Section 297(2)(d) was confined to the machinery for reassessment of escaped income and did not carry forward a substantive liability-creating provision like Section 171(6). The result was that pre-1962 assessments could not be enforced personally against the HUF members under the new Act. Case-Laws Income Tax Thu, 18 Dec 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296593