COMMISSIONER OF INCOME-TAX, PATIALA & ORS. vs M/s. SHAHZADA NAND & SONS & ORS.

The Supreme Court ruled that Section 34(1)(a) of the Indian Income-tax Act, 1922, as amended by the Finance Act 1956, allows for the issuance of notices for escaped income 'at any time', thereby superseding the limitations previously imposed. The Court clarified that Section 34(1A) does not conflict with Section 34(1)(a) but rather provides a specific power that expired on April 1, 1956. Consequently, the High Court's decision favoring the respondents was overturned, affirming the validity of the notice issued by the Income-tax Officer for the assessment year 1945-46.