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    <title>1961 (4) TMI 8 - Supreme Court</title>
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    <description>Pre-Constitution settlement, demand notice and recovery proceedings under the income-tax investigation scheme cannot be retrospectively invalidated under Article 14 where they were completed before the Constitution commenced. Discriminatory procedures continuing after commencement are distinguishable. Section 8A(2) of the Taxation on Income (Investigation Commission) Act, 1947 operates as a recovery mechanism for an accepted settlement, applying income-tax recovery machinery as though the settled amount were tax arrears. It does not require a fresh assessment before recovery because no such requirement appears in its text.</description>
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      <description>Pre-Constitution settlement, demand notice and recovery proceedings under the income-tax investigation scheme cannot be retrospectively invalidated under Article 14 where they were completed before the Constitution commenced. Discriminatory procedures continuing after commencement are distinguishable. Section 8A(2) of the Taxation on Income (Investigation Commission) Act, 1947 operates as a recovery mechanism for an accepted settlement, applying income-tax recovery machinery as though the settled amount were tax arrears. It does not require a fresh assessment before recovery because no such requirement appears in its text.</description>
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