COMMISSIONER OF INCOME-TAX, BOMBAY vs ROBERT J. SAS

The Supreme Court ruled that notices issued under Section 34(1) of the Indian Income-tax Act, 1922, were time-barred as they were served beyond the four-year limitation period. The Court clarified that under Section 23A(1), the deemed distribution of dividends occurs on the date of the general meeting, December 4, 1948, and not on the later date when the dividend should have been declared. Consequently, the Income-tax Officer lacked jurisdiction to assess the assessees, leading to the dismissal of the appeals by the Commissioner of Income-Tax.