KALAWATI DEVI HARLALKA vs COMMISSIONER OF INCOME-TAX, WEST BENGAL & ORS.

The Supreme Court held that the proceedings initiated by the Commissioner of Income-tax under Section 33B of the Income-tax Act, 1922, were valid as they fell under the expression 'proceedings for the assessment' in Section 297(2)(a) of the Income-tax Act, 1961. The Court clarified that 'assessment' encompasses the entire procedure for determining tax liability, and thus, the initiation of proceedings was permissible despite the repeal of the 1922 Act. Additionally, the Court ruled that Section 298 of the 1961 Act was valid and applicable to the case at hand, affirming the legality of the Income-tax (Removal of Difficulties) Order, 1962.