https://www.taxtmi.com/caselaws?id=49445 The phrase "for any year" in section 34(1)(a) denotes the assessment year rather than the accounting (previous) year; this construction follows section 22's requirement that returns be made for the assessment year, the charging framework of section 3, and historical legislative practice describing assessments by reference to assessment years. The context of clause (a) - disclosure of material facts "necessary for his assessment for that year" - and prior decisions support computing limitation from the end of the assessment year. Adopting the accounting-year meaning would produce inconsistent limitation start points across income sources and is therefore rejected, favouring the Revenue. en-us Thu, 05 Oct 1961 00:00:00 +0530 Fri, 29 Aug 2014 10:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49445 The phrase "for any year" in section 34(1)(a) denotes the assessment year rather than the accounting (previous) year; this construction follows section 22's requirement that returns be made for the assessment year, the charging framework of section 3, and historical legislative practice describing assessments by reference to assessment years. The context of clause (a) - disclosure of material facts "necessary for his assessment for that year" - and prior decisions support computing limitation from the end of the assessment year. Adopting the accounting-year meaning would produce inconsistent limitation start points across income sources and is therefore rejected, favouring the Revenue. Case-Laws Income Tax Thu, 05 Oct 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49445