https://www.taxtmi.com/caselaws?id=37830 Section 147(a) read with Section 148 of the Income-tax Act, 1961 was considered against the background of limitation under Section 34(1)(a) of the 1922 Act for reassessment of escaped income. The Court examined the 1948 and 1956 amendments to Section 34 and held that the 1959 insertion of Section 34(4) manifested legislative intent to revive or validate notices even after expiry of the earlier eight-year period. On that construction, the assessee's vested limitation defence was displaced, and reopening under the successor statute was treated as valid. en-us Thu, 27 Apr 1978 00:00:00 +0530 Thu, 01 Apr 2010 12:47:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37830 Section 147(a) read with Section 148 of the Income-tax Act, 1961 was considered against the background of limitation under Section 34(1)(a) of the 1922 Act for reassessment of escaped income. The Court examined the 1948 and 1956 amendments to Section 34 and held that the 1959 insertion of Section 34(4) manifested legislative intent to revive or validate notices even after expiry of the earlier eight-year period. On that construction, the assessee's vested limitation defence was displaced, and reopening under the successor statute was treated as valid. Case-Laws Income Tax Thu, 27 Apr 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37830