https://www.taxtmi.com/caselaws?id=38325 Reassessment under section 34(1)(b) to tax deemed dividend as agent income was held time-barred because the revenue had proceeded before the Tribunal on the footing that the assessee was a deemed agent under section 43, attracting the second proviso to section 34(1). The alternative argument that the assessee should be treated as an agent under section 40(2) could not be entertained in reference under section 66 because it had not been raised or argued before the Tribunal. On the issues actually before it, the Tribunal was therefore justified in holding the reassessment notice barred by limitation. en-us Fri, 08 Jul 1977 00:00:00 +0530 Mon, 05 Apr 2010 14:06:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38325 Reassessment under section 34(1)(b) to tax deemed dividend as agent income was held time-barred because the revenue had proceeded before the Tribunal on the footing that the assessee was a deemed agent under section 43, attracting the second proviso to section 34(1). The alternative argument that the assessee should be treated as an agent under section 40(2) could not be entertained in reference under section 66 because it had not been raised or argued before the Tribunal. On the issues actually before it, the Tribunal was therefore justified in holding the reassessment notice barred by limitation. Case-Laws Income Tax Fri, 08 Jul 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38325