https://www.taxtmi.com/caselaws?id=49393 The second proviso to section 34(3) of the Indian Income-tax Act, 1922 lifts the time bar only for action taken to give effect to a finding or direction contained in appellate, revisional, reference or review orders, but it does not enlarge the jurisdiction of the authority making those orders. A finding or direction must be necessary for disposal of the matter within that authority's jurisdiction, so the proviso cannot justify reopening escaped income of a different assessment year. The provision also creates a permissible classification between cases where escaped income is discovered in such proceedings and other cases, and is not violative of Article 14. The article notes a dissenting view for broader construction. en-us Wed, 29 Jan 1964 00:00:00 +0530 Sat, 28 Feb 2015 11:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49393 The second proviso to section 34(3) of the Indian Income-tax Act, 1922 lifts the time bar only for action taken to give effect to a finding or direction contained in appellate, revisional, reference or review orders, but it does not enlarge the jurisdiction of the authority making those orders. A finding or direction must be necessary for disposal of the matter within that authority's jurisdiction, so the proviso cannot justify reopening escaped income of a different assessment year. The provision also creates a permissible classification between cases where escaped income is discovered in such proceedings and other cases, and is not violative of Article 14. The article notes a dissenting view for broader construction. Case-Laws Income Tax Wed, 29 Jan 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49393