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1979 (8) TMI 4 - SUPREME COURTWhether the reassessment sought to be made by the ITO on the assessee-trust under s. 34(1)(b), was time barred - assessee-trust was clearly a stranger to the assessment proceedings of S. Raghubir Singh and it was not " any person " within the meaning of the second proviso to s. 34(3). The High Court was, therefore, right in taking the view that the second proviso to s. 34(3) was not attracted and the reassessment proceedings against the assessee-trust were barred by time.
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