INCOME-TAX OFFICER, AWARD, SITAPUR vs MURLITDHAR BHAGWANDAS, LAKHIMPUR KHERI

The Supreme Court held that the proviso to sub-section (3) of Section 34 of the Indian Income-tax Act, 1922 does not extend the time limit for issuing notices regarding escaped assessments for years not under appeal. The Court ruled that the notice issued under Section 34(1)(a) for the assessment year 1949-50 was time-barred as it pertained to a year not subject to the appeal. Consequently, the High Court's decision to quash the notice was upheld, affirming the importance of adhering to statutory time limits in tax assessments.