COMMISSIONER OF INCOME TAX, U.P. vs M/S. MOHD. SHAKOOR MOHD. BASHIR

The Supreme Court held that under Section 34(3) of the Indian Income Tax Act, 1922, the expression 'finding' refers to a necessary determination for the assessment year in question. The Appellate Assistant Commissioner did not provide a requisite finding regarding the respondents' continuation of the tobacco business or any income derived from it during the relevant assessment years. Consequently, the Court dismissed the appeals, affirming the High Court's ruling that the notices issued under Section 34(1)(a) were barred by time and that the Appellate Assistant Commissioner lacked authority to direct action against the assessee.