COMMISSIONER OF INCOME-TAX vs SARDAR LAKHMIR SINGH

The Supreme Court held that the assessment made after four years was barred under Section 34(3) of the Indian Income-tax Act, 1922, as it was not completed within the prescribed time. The Court ruled that the second proviso to Section 34(3) did not revive the power to assess once it had become barred and that Section 31 of the Amending Act, 1953, was not applicable to the case at hand. The dissenting judges argued that the assessments were valid and saved by the amended provisions, but the majority opinion prevailed, confirming the High Court's ruling in favor of the assessee.