https://www.taxtmi.com/caselaws?id=49491 Section 23A did not itself authorise a fresh assessment of deemed dividend; it only deemed the shareholder's proportionate share of undistributed profits to form part of total income. The tax had therefore to be brought to charge through the Act's assessment or reassessment machinery, including section 34 where that procedure applied. Because no notice under section 34 was issued, the reassessment was unsustainable and the assessment invalid. The text states that action under section 34 was necessary and that the appeal was dismissed. en-us Tue, 10 Jan 1961 00:00:00 +0530 Sun, 31 Aug 2014 16:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49491 Section 23A did not itself authorise a fresh assessment of deemed dividend; it only deemed the shareholder's proportionate share of undistributed profits to form part of total income. The tax had therefore to be brought to charge through the Act's assessment or reassessment machinery, including section 34 where that procedure applied. Because no notice under section 34 was issued, the reassessment was unsustainable and the assessment invalid. The text states that action under section 34 was necessary and that the appeal was dismissed. Case-Laws Income Tax Tue, 10 Jan 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49491