THE COMMISSIONER OF INCOME-TAX, BIHAR & ORISSA. vs MAHARAJA PRATAPSINGH BAHADUR OF GIDHAUR.

The Supreme Court held that the notices issued by the Income-tax Officer under Section 34 of the Indian Income-tax Act, 1922, without the approval of the Commissioner were invalid due to subsequent amendments made by the Income-tax and Business Profits Tax (Amendment) Act, 1948. The Court clarified that Section 6 of the General Clauses Act, 1897, did not apply as the amended Section 34 indicated a different legislative intent, making the new provisions retroactive to March 30, 1948. Consequently, the assessments based on the invalid notices were also deemed void.