https://www.taxtmi.com/caselaws?id=29329 Reopening under section 148 of the Income-tax Act, 1961 for assessment year 1950-51 was held invalid because the power to reopen had already become time-barred under the Indian Income-tax Act, 1922 before the new Act commenced. The later notice issued in 1965 was therefore without jurisdiction, and the attempted reliance on alleged concealments from later years could not extend the statutory limitation beyond the relevant year or the years covered by the proviso. Consent, settlement, or subsequent conduct could not cure the jurisdictional defect, and the rectification application under section 154 was maintainable. The assessee succeeded. en-us Tue, 16 Mar 1982 00:00:00 +0530 Fri, 12 Mar 2010 12:13:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=29329 Reopening under section 148 of the Income-tax Act, 1961 for assessment year 1950-51 was held invalid because the power to reopen had already become time-barred under the Indian Income-tax Act, 1922 before the new Act commenced. The later notice issued in 1965 was therefore without jurisdiction, and the attempted reliance on alleged concealments from later years could not extend the statutory limitation beyond the relevant year or the years covered by the proviso. Consent, settlement, or subsequent conduct could not cure the jurisdictional defect, and the rectification application under section 154 was maintainable. The assessee succeeded. Case-Laws Income Tax Tue, 16 Mar 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=29329