COMMISSIONER OF INCOME TAX, WEST BENGAL, vs BALKRISHAN MALHOTRA

The Supreme Court addressed the interpretation of Section 34(3) of the Indian Income Tax Act, 1922, determining that the assessment is not complete until the tax is computed and a demand notice is issued. The Court held that the assessment made on March 8, 1954, was incomplete as the tax was determined only on March 31, 1954, thus rendering the assessment time-barred. The High Court's decision favoring the assessee was upheld, confirming the applicability of the time limitation under Section 34(3).