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    <title>1981 (4) TMI 40 - BOMBAY High Court</title>
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    <description>Reassessment beyond the normal limitation period could not be saved by the second proviso to section 34(3) unless a finding necessary to decide the appeal concerned a person legally and intimately connected with the appealed assessment. An incidental statement affecting executors of an independent estate did not constitute a binding finding or direction. The reassessment notices were therefore time-barred. Reassessment also could not rest on failure to make a full and true disclosure where estate income had been disclosed and the income-tax authority had chosen to assess it in another person&#039;s hands. Rectification was unavailable because a consciously reached assessment decision was not a mistake apparent from the record merely due to a later contrary view.</description>
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    <pubDate>Tue, 14 Apr 1981 00:00:00 +0530</pubDate>
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      <title>1981 (4) TMI 40 - BOMBAY High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=29426</link>
      <description>Reassessment beyond the normal limitation period could not be saved by the second proviso to section 34(3) unless a finding necessary to decide the appeal concerned a person legally and intimately connected with the appealed assessment. An incidental statement affecting executors of an independent estate did not constitute a binding finding or direction. The reassessment notices were therefore time-barred. Reassessment also could not rest on failure to make a full and true disclosure where estate income had been disclosed and the income-tax authority had chosen to assess it in another person&#039;s hands. Rectification was unavailable because a consciously reached assessment decision was not a mistake apparent from the record merely due to a later contrary view.</description>
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      <pubDate>Tue, 14 Apr 1981 00:00:00 +0530</pubDate>
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