https://www.taxtmi.com/caselaws?id=39861 Reassessment notices under the Income-tax Act were held unsustainable where the earlier assessment had already become time-barred under the 1922 Act, or where no valid regular assessment had been completed, and the later statute could not convert that position into escaped assessment. The Court also noted that full disclosure of primary facts negatived failure-to-disclose jurisdiction, and no genuine belief that income had escaped assessment was shown. Further, the saving provisions for action in consequence of a finding or direction applied only within the scope of the earlier appellate proceeding and against the proper assessee; they did not extend to the firm or an alleged association of persons not covered by that proceeding. The notices and related action were struck down. en-us Tue, 23 Apr 1974 00:00:00 +0530 Tue, 20 Apr 2010 17:15:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39861 Reassessment notices under the Income-tax Act were held unsustainable where the earlier assessment had already become time-barred under the 1922 Act, or where no valid regular assessment had been completed, and the later statute could not convert that position into escaped assessment. The Court also noted that full disclosure of primary facts negatived failure-to-disclose jurisdiction, and no genuine belief that income had escaped assessment was shown. Further, the saving provisions for action in consequence of a finding or direction applied only within the scope of the earlier appellate proceeding and against the proper assessee; they did not extend to the firm or an alleged association of persons not covered by that proceeding. The notices and related action were struck down. Case-Laws Income Tax Tue, 23 Apr 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39861