PANNALAL NANDLAL BHANDARI vs THE COMMISSIONER OF INCOME-TAX, BOMBAY CITY, BOMBAY.

The Supreme Court held that non-residents are not exempt from the obligation to submit income tax returns under Section 22(1) of the Indian Income Tax Act, 1922. The Court clarified that the expression 'every person' includes all liable to pay tax, and failure to submit a return constitutes an omission under Section 34(1)(a). The notices issued for assessment were deemed valid as they were within the limitation period prescribed by Section 34(1)(a), thus upholding the assessments made by the Income Tax Officer.