https://www.taxtmi.com/caselaws?id=28252 The second proviso to section 34(3) of the Indian Income-tax Act, 1922 was construed narrowly: "any person" means a person intimately connected with the assessment under appeal and liable for the income forming part of that assessment. On that basis, the non-resident company was treated as properly connected because its income was assessed through its resident agent and the reassessment directions related to the same income and assessment years. A valid appellate direction by the Appellate Assistant Commissioner could therefore be issued against the proper assessee, and the reassessment notices were not barred by limitation. en-us Fri, 13 Aug 1982 00:00:00 +0530 Sat, 20 Feb 2010 10:27:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28252 The second proviso to section 34(3) of the Indian Income-tax Act, 1922 was construed narrowly: "any person" means a person intimately connected with the assessment under appeal and liable for the income forming part of that assessment. On that basis, the non-resident company was treated as properly connected because its income was assessed through its resident agent and the reassessment directions related to the same income and assessment years. A valid appellate direction by the Appellate Assistant Commissioner could therefore be issued against the proper assessee, and the reassessment notices were not barred by limitation. Case-Laws Income Tax Fri, 13 Aug 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28252