Supreme Court · 1998 INSC 96 · Decided 17 February 1998

Hungerford Investment Trust LTD. v. Income Tax Officers and ORS.

Court
Supreme Court of India
Citation
1998 INSC 96 · [1998] 1 S.C.R. 905
Case number
CIVIL APPEAL No. 474/1984
Decided
17 February 1998
Bench
SUJATA V. MANOHAR, D.P. WADHWA (2-judge bench)
Outcome
Dismissed
Case type
Civil
Acts & sections cited
Income Tax Act Section 34(3), 31

Headnote

B ~ """ Income Tax Act, 1922-Section 34(3)-lncome escaping assessment- Limitation-Expression ''the assessee or any other person'' occurring in Section 34-Undistributed income of the Indian Company under an order passed under Section 23-A (prior to amendment in 1955) deemed to be to tax, !TO issued notices to the Indian Company as agents for the Non- Resident Company and directly to the Non-resident Company-Returns filed pursuant to notices both by the Indian Company and by the non-resident company through the cover letter of Indian company being agents-ITO D ~ making

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