1994 (1) TMI 80

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....facts leading to the filing of this case are The assessee is an individual. The accounting year is the year ended on March 31, 1968, corresponding to the assessment year 1968-69. Certain land belonging to the assessee was acquired and compensation was paid on December 11, 1967. Later, on July 3, 1972, the assessee received an additional sum. The Income-tax Officer assessed the enhanced compensa....

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.... be assumed because in every part of the proceedings section 147(a) of the Act had been stressed. The Appellate Tribunal also considered whether the assessment could be regarded as one made for giving effect to a finding and held that since section 147(a) of the Act had been specifically invoked, the assessment could not be affirmed without fulfilling the ingredients of that section. At the ins....

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....849 : We find that the court, while considering the question of bar of limitation, pointed out that specific provision for removing the bar of limitation in respect of an assessment giving effect to a finding may not have been called for in case a reassessment made in order to give effect to a finding was considered to be a separate class of assessment. However, we are of the opinion that in a ....