THE COMMISSIONER OF INCOME TAX,BOMBAY CITY 1, BOMBAY vs M/S. NARSEE NAGSEE AND CO., BOMBAY.

The Supreme Court held that under Section 11(1) of the Business Profits Tax Act, 1947, a notice cannot be issued beyond the four-year limitation period specified in Section 14 of the Act. The Court interpreted 'profits escaping assessment' to include cases where no assessment was made due to the late issuance of a notice. The majority opinion established that both sections must be read together, affirming the High Court's decision that the notice was invalid as it was served beyond the statutory period.