S. S. GADGIL, INCOME-TAX OFFICER, BOMBAY vs LAL AND COMPANY

The Supreme Court ruled that the Income-tax Officer's notice issued under Section 34 of the Indian Income-tax Act, 1922, was barred as it was issued after the expiry of the one-year limit for assessment, despite an amendment extending the period to two years. The Court held that the amendment could not be applied retrospectively to allow the issuance of the notice, as the authority to issue such notice had lapsed before the amendment came into effect. Thus, the proceedings initiated by the Income-tax Officer were invalid.