The Commissioner (Appeals) allowed my appeal for one year and said in passing that the amount really belongs to an earlier year. The officer has now reopened that earlier year and calls the remark a finding. Is it one?
Probably not. A Constitution Bench of five judges construed the second proviso to s.34(3) of the 1922 Act — the ancestor of s.150 — and held by three to two that it lifts the time limit only for the year that was actually before the appellate, revisional or reference authority. The majority adopted the Allahabad High Court's definition of “finding” in Pt. Hazari Lal and added that a finding can only be what was necessary for the disposal of an appeal in respect of the assessment of a particular year. A “direction” means one the authority is empowered to give under the sections named in the proviso, and s.31 gave the Appellate Assistant Commissioner no power to order an assessment for a year that was not before him. The words “any person” in the proviso were confined to a person intimately connected with the assessment of the year under appeal. The Revenue's appeal was dismissed with costs. Raghubar Dayal and Mudholkar JJ dissented.
Decided by the Supreme Court (Supreme Court of India, Constitution Bench of five — B.P. Sinha CJ, K. Subba Rao, Raghubar Dayal, N. Rajagopala Ayyangar and J.R. Mudholkar JJ. The majority judgment was delivered by Subba Rao J; Mudholkar J delivered the dissent, with which Raghubar Dayal J agreed.) on 1964-01-29, reported as Civil Appeal No. 130 of 1962, by special leave from the judgment and decree of the Allahabad High Court dated 17 March 1959 in Miscellaneous Writ Petition No. 280 of 1958; the judgment carries the citations AIR 1965 SC 342 and [1964] 6 SCR 411, and is cited in later judgments as [1964] 52 ITR 335. It bears on section 34 of the Indian Income-tax Act, 1922, section 34(3) of the Indian Income-tax Act, 1922, section 150, section 150(1), section 150(2), section 149, section 148, section 153(3), section 283 (Act of 2025) of the Income Tax Act 1961, in Reassessment & Reopening, Assessment & Scrutiny and How Tax Law Is Read matters.
This is the first question to ask about any notice that claims the benefit of s.150, and it is asked before limitation, before sanction and before anything else. If the passage the officer is relying on is not a finding or a direction within this decision, s.150(1) never engaged, and the notice has to stand or fall under s.149 like any other. That is a complete answer, and it is available far more often than practitioners use it, because appellate orders are full of observations about other years that nobody needed for the year being decided. The test the majority gave is a hard one for the Revenue: not whether the appellate authority said it, not whether it was deliberate, but whether the appellate authority had to decide it to dispose of the year before it. An observation that the receipt belongs to an earlier year, made while deleting an addition, usually fails that test, because the deletion stands whether or not the earlier year is named. The companion holding on “direction” closes the other door: a first appellate authority has no power to order an assessment for a year not before it, so words that read as an instruction to assess another year are outside the section whatever they say. Two guards, and each one is enough on its own.
Binding on every court and authority in India.
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The respondent was a firm carrying on business in different lines. For assessment year 1949-50 it was assessed under s.23(4) to the best of the officer's judgment. That assessment was cancelled under s.27 on 27 September 1955. Before the cancellation the officer had found that interest of Rs 88,737, in the shape of U.P. Encumbered Estates Act bonds received by the firm from third parties, had escaped assessment, and he issued a notice under s.34(1)(a) for 1949-50. In the fresh assessment he brought that amount to tax in 1949-50. The firm appealed. On 4 December 1957 the Appellate Assistant Commissioner held that the bonds had been received in the earlier accounting year and recorded: “I, therefore, hold that the amount in dispute should be deleted from the assessment for 1949-50 and that, instead, the Income-tax Officer should take steps to assess the amount for the assessment year 1948-49.” The officer acted on that the next day: a notice under s.34(1) for assessment year 1948-49 was served on the firm on 5 December 1957, long after the ordinary period for that year had run out. The firm went to the Allahabad High Court, which quashed the notice on 17 March 1959. The Income-tax Officer appealed by special leave, relying on the second proviso to s.34(3), which lifted the time bar for “an assessment or reassessment made on the assessee or any person in consequence of or to give effect to any finding or direction contained in an order under s. 31, s. 33, s. 33A, s. 33B, s. 66 or s. 66A”.
The appeal was dismissed. The question the Court framed for itself was whether the second proviso to s.34(3) saves the time limit in s.34(1) in respect of an escaped assessment of a year other than the year that is the subject matter of the appeal or revision, and the majority answered it in the negative: “In the result, we hold that the said provision would not save the time-limit prescribed under sub-s. (1) of s. 34 of the Act in respect of an escaped assessment of a year other than that which is the subject-matter of the appeal or the revision.” Three things were decided on the way there. On “finding”, the majority took the definition the Allahabad High Court had given in Pt. Hazari Lal, agreed with it, and put its own gloss on it: “A ‘finding’, therefore, can be only that which is necessary for the disposal of an appeal in respect of an assessment of a particular year.” On “direction”, it held that the word “cannot be construed in vacuum, but must be collated to the directions which the Appellate Assistant Commissioner can give under s. 31”, and that of that section “no power is conferred on him to make an order or issue directions in respect of an assessment of a year which was not the subject-matter of the appeal”. On “any person”, it held that the expression “must be confined to a person intimately connected in the aforesaid sense with the assessment of the year under appeal”. Raghubar Dayal and Mudholkar JJ dissented, Mudholkar J taking the view that a conclusion need not be final or ultimate to be a finding. The Court's order records: “In view of the judgment of the majority, the appeal fails and is dismissed with costs.”
The majority read the proviso as a lifting of a ban and not as a grant of power. Its words are: “The lifting of the ban was only to give effect to the orders that may be made by the appellate, revisional or reviewing tribunal within the scope of its jurisdiction”, and “It only lifts the ban of limitation in respect of certain assessments made under certain provisions of the Act and the lifting of the ban cannot be so construed as to increase the jurisdiction of the Tribunals under the relevant section.” From that everything else follows. Each of the sections named in the proviso confers a jurisdiction that is tied to a particular assessment: the Appellate Assistant Commissioner under s.31 decides the appeal before him, and the jurisdiction of the High Court or the Supreme Court under s.66 or s.66B “is far more limited and it is confined only to the questions referred to them”. So “the assessment or reassessment made under the said sections or pursuant to the orders or directions made thereunder must necessarily relate to the assessment of the year under review, revision or appeal as the case may be”. A finding about some other year is not something the authority had to reach in order to decide the appeal, and a direction about some other year is not something the authority had power to give. The majority also declined to read the proviso as removing limitation at large, pointing out that if that had been the intention the proviso would have been attached to s.34(1), which governs the issue of the notice, rather than to s.34(3), which governs the completion of an assessment.
A 'finding', therefore, can be only that which is necessary for the disposal of an appeal in respect of an assessment of a particular year.
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Handle my notice → Ask a CA on WhatsAppProbably not. A Constitution Bench of five judges construed the second proviso to s.34(3) of the 1922 Act — the ancestor of s.150 — and held by three to two that it lifts the time limit only for the year that was actually before the appellate, revisional or reference authority. The majority adopted the Allahabad High Court's definition of “finding” in Pt. Hazari Lal and added that a finding can only be what was necessary for the disposal of an appeal in respect of the assessment of a particular year. A “direction” means one the authority is empowered to give under the sections named in the proviso, and s.31 gave the Appellate Assistant Commissioner no power to order an assessment for a year that was not before him. The words “any person” in the proviso were confined to a person intimately connected with the assessment of the year under appeal. The Revenue's appeal was dismissed with costs. Raghubar Dayal and Mudholkar JJ dissented. This was decided by the Supreme Court (Supreme Court of India, Constitution Bench of five — B.P. Sinha CJ, K. Subba Rao, Raghubar Dayal, N. Rajagopala Ayyangar and J.R. Mudholkar JJ. The majority judgment was delivered by Subba Rao J; Mudholkar J delivered the dissent, with which Raghubar Dayal J agreed.) and bears on section 34 of the Indian Income-tax Act, 1922, section 34(3) of the Indian Income-tax Act, 1922, section 150, section 150(1), section 150(2), section 149, section 148, section 153(3), section 283 (Act of 2025) of the Income Tax Act 1961. It is reported as Civil Appeal No. 130 of 1962, by special leave from the judgment and decree of the Allahabad High Court dated 17 March 1959 in Miscellaneous Writ Petition No. 280 of 1958; the judgment carries the citations AIR 1965 SC 342 and [1964] 6 SCR 411, and is cited in later judgments as [1964] 52 ITR 335. This is the first question to ask about any notice that claims the benefit of s.150, and it is asked before limitation, before sanction and before anything else. If the passage the officer is relying on is not a finding or a direction within this decision, s.150(1) never engaged, and the notice has to stand or fall under s.149 like any other. That is a complete answer, and it is available far more often than practitioners use it, because appellate orders are full of observations about other years that nobody needed for the year being decided. The test the majority gave is a hard one for the Revenue: not whether the appellate authority said it, not whether it was deliberate, but whether the appellate authority had to decide it to dispose of the year before it. An observation that the receipt belongs to an earlier year, made while deleting an addition, usually fails that test, because the deletion stands whether or not the earlier year is named. The companion holding on “direction” closes the other door: a first appellate authority has no power to order an assessment for a year not before it, so words that read as an instruction to assess another year are outside the section whatever they say. Two guards, and each one is enough on its own. If it applies to you, the first step is this: Get the appellate order and read the passage the officer is relying on in full, in its place in the order. The question is not whether the words are emphatic but whether the appellate authority had to decide that point to dispose of the year before it.
The respondent was a firm carrying on business in different lines. For assessment year 1949-50 it was assessed under s.23(4) to the best of the officer's judgment. That assessment was cancelled under s.27 on 27 September 1955. Before the cancellation the officer had found that interest of Rs 88,737, in the shape of U.P. Encumbered Estates Act bonds received by the firm from third parties, had escaped assessment, and he issued a notice under s.34(1)(a) for 1949-50. In the fresh assessment he brought that amount to tax in 1949-50. The firm appealed. On 4 December 1957 the Appellate Assistant Commissioner held that the bonds had been received in the earlier accounting year and recorded: “I, therefore, hold that the amount in dispute should be deleted from the assessment for 1949-50 and that, instead, the Income-tax Officer should take steps to assess the amount for the assessment year 1948-49.” The officer acted on that the next day: a notice under s.34(1) for assessment year 1948-49 was served on the firm on 5 December 1957, long after the ordinary period for that year had run out. The firm went to the Allahabad High Court, which quashed the notice on 17 March 1959. The Income-tax Officer appealed by special leave, relying on the second proviso to s.34(3), which lifted the time bar for “an assessment or reassessment made on the assessee or any person in consequence of or to give effect to any finding or direction contained in an order under s. 31, s. 33, s. 33A, s. 33B, s. 66 or s. 66A”. The matter was decided on 1964-01-29 by the Supreme Court (Supreme Court of India, Constitution Bench of five — B.P. Sinha CJ, K. Subba Rao, Raghubar Dayal, N. Rajagopala Ayyangar and J.R. Mudholkar JJ. The majority judgment was delivered by Subba Rao J; Mudholkar J delivered the dissent, with which Raghubar Dayal J agreed.). On those facts the Supreme Court held as follows. The appeal was dismissed. The question the Court framed for itself was whether the second proviso to s.34(3) saves the time limit in s.34(1) in respect of an escaped assessment of a year other than the year that is the subject matter of the appeal or revision, and the majority answered it in the negative: “In the result, we hold that the said provision would not save the time-limit prescribed under sub-s. (1) of s. 34 of the Act in respect of an escaped assessment of a year other than that which is the subject-matter of the appeal or the revision.” Three things were decided on the way there. On “finding”, the majority took the definition the Allahabad High Court had given in Pt. Hazari Lal, agreed with it, and put its own gloss on it: “A ‘finding’, therefore, can be only that which is necessary for the disposal of an appeal in respect of an assessment of a particular year.” On “direction”, it held that the word “cannot be construed in vacuum, but must be collated to the directions which the Appellate Assistant Commissioner can give under s. 31”, and that of that section “no power is conferred on him to make an order or issue directions in respect of an assessment of a year which was not the subject-matter of the appeal”. On “any person”, it held that the expression “must be confined to a person intimately connected in the aforesaid sense with the assessment of the year under appeal”. Raghubar Dayal and Mudholkar JJ dissented, Mudholkar J taking the view that a conclusion need not be final or ultimate to be a finding. The Court's order records: “In view of the judgment of the majority, the appeal fails and is dismissed with costs.”
The majority read the proviso as a lifting of a ban and not as a grant of power. Its words are: “The lifting of the ban was only to give effect to the orders that may be made by the appellate, revisional or reviewing tribunal within the scope of its jurisdiction”, and “It only lifts the ban of limitation in respect of certain assessments made under certain provisions of the Act and the lifting of the ban cannot be so construed as to increase the jurisdiction of the Tribunals under the relevant section.” From that everything else follows. Each of the sections named in the proviso confers a jurisdiction that is tied to a particular assessment: the Appellate Assistant Commissioner under s.31 decides the appeal before him, and the jurisdiction of the High Court or the Supreme Court under s.66 or s.66B “is far more limited and it is confined only to the questions referred to them”. So “the assessment or reassessment made under the said sections or pursuant to the orders or directions made thereunder must necessarily relate to the assessment of the year under review, revision or appeal as the case may be”. A finding about some other year is not something the authority had to reach in order to decide the appeal, and a direction about some other year is not something the authority had power to give. The majority also declined to read the proviso as removing limitation at large, pointing out that if that had been the intention the proviso would have been attached to s.34(1), which governs the issue of the notice, rather than to s.34(3), which governs the completion of an assessment. In the words reproduced by the source cited on this page: "A 'finding', therefore, can be only that which is necessary for the disposal of an appeal in respect of an assessment of a particular year."
It was decided by the Supreme Court on 1964-01-29 and is reported as Civil Appeal No. 130 of 1962, by special leave from the judgment and decree of the Allahabad High Court dated 17 March 1959 in Miscellaneous Writ Petition No. 280 of 1958; the judgment carries the citations AIR 1965 SC 342 and [1964] 6 SCR 411, and is cited in later judgments as [1964] 52 ITR 335. Binding on every court and authority in India. A Supreme Court decision binds every assessing officer, every Commissioner (Appeals), every bench of the Income Tax Appellate Tribunal and every High Court in India. An officer who declines to follow it is acting contrary to law, and that refusal is itself a ground of appeal. On section 34 of the Indian Income-tax Act, 1922, section 34(3) of the Indian Income-tax Act, 1922, section 150, section 150(1), section 150(2), section 149, section 148, section 153(3), section 283 (Act of 2025), the practical question is whether the facts of your own notice match the facts of this case closely enough for the same rule to apply.
It helps the taxpayer. The appeal was dismissed. The question the Court framed for itself was whether the second proviso to s.34(3) saves the time limit in s.34(1) in respect of an escaped assessment of a year other than the year that is the subject matter of the appeal or revision, and the majority answered it in the negative: “In the result, we hold that the said provision would not save the time-limit prescribed under sub-s. (1) of s. 34 of the Act in respect of an escaped assessment of a year other than that which is the subject-matter of the appeal or the revision.” Three things were decided on the way there. On “finding”, the majority took the definition the Allahabad High Court had given in Pt. Hazari Lal, agreed with it, and put its own gloss on it: “A ‘finding’, therefore, can be only that which is necessary for the disposal of an appeal in respect of an assessment of a particular year.” On “direction”, it held that the word “cannot be construed in vacuum, but must be collated to the directions which the Appellate Assistant Commissioner can give under s. 31”, and that of that section “no power is conferred on him to make an order or issue directions in respect of an assessment of a year which was not the subject-matter of the appeal”. On “any person”, it held that the expression “must be confined to a person intimately connected in the aforesaid sense with the assessment of the year under appeal”. Raghubar Dayal and Mudholkar JJ dissented, Mudholkar J taking the view that a conclusion need not be final or ultimate to be a finding. The Court's order records: “In view of the judgment of the majority, the appeal fails and is dismissed with costs.” It arises in Reassessment & Reopening, Assessment & Scrutiny and How Tax Law Is Read matters, on section 34 of the Indian Income-tax Act, 1922, section 34(3) of the Indian Income-tax Act, 1922, section 150, section 150(1), section 150(2), section 149, section 148, section 153(3), section 283 (Act of 2025) of the Income Tax Act 1961, and was decided by Supreme Court of India, Constitution Bench of five — B.P. Sinha CJ, K. Subba Rao, Raghubar Dayal, N. Rajagopala Ayyangar and J.R. Mudholkar JJ. The majority judgment was delivered by Subba Rao J; Mudholkar J delivered the dissent, with which Raghubar Dayal J agreed.. Before relying on it, read the source linked on this page and check whether it has since been distinguished, overruled or overtaken by an amendment to the Income Tax Act. In practice the steps that follow from it are these. If the appellate authority could have given the assessee the same relief without saying anything about the other year, the observation is incidental. On this authority it is not a finding, and s.150(1) never engaged — which means s.149 applies to the notice in the ordinary way. Ask separately whether it is a direction. A direction has to be one the authority was empowered to give in that appeal, reference or revision. A first appellate authority deciding one year has no power to order an assessment for another. Check that the finding is about you. The proviso construed here reached the assessee or a person intimately connected with the assessment of the year under appeal, not anyone the order happens to mention. Put the point in writing at the s.148A stage rather than saving it, and say in terms which sentence of the appellate order is said to be the finding and why it was not necessary to the year decided. Take s.150(2) as a separate and later question. Even where there is a real finding, s.150(2) asks whether the year could still have been assessed on the date the order under appeal was made. For any notice issued on or after 1 February 2026, also work the new s.150(3) three-month period, which runs from the end of the quarter in which the certified copy of the order reached the jurisdictional Principal Commissioner or Commissioner.
Still good law. Nothing doubting it was found, and the Supreme Court has twice restated it. In Commissioner of Income-tax, Bihar v Banwari Lal Agarwal, decided 18 January 1971 by Shah CJ, Hegde and Grover JJ, the Court said the expressions in the second proviso mean “respectively, a finding necessary for giving relief in respect of the assessment for the year in question, and a direction which the appellate or revisional authority, as the case may be is empowered to give under the sections mentioned in that proviso”. In Rajinder Nath v Commissioner of Income-tax, Delhi, decided 13 August 1979 by Pathak and Bhagwati JJ in Civil Appeals Nos. 1864-1869 of 1972, the Court carried the same construction into s.153(3)(ii) of the 1961 Act: a finding “must be a finding necessary for the disposal of the particular case, that is to say, in respect of the particular assessee and in relation to the particular assessment year”, an incidental finding is not enough, and a direction “must be an express direction necessary for the disposal of the case before the authority or court” and one “which the authority or court is empowered to give”. Rajinder Nath adds that where the officer is left an option whether or not to act, that is not a direction at all. The words survive. Section 150(1) of the 1961 Act uses the same expression, “any finding or direction contained in an order”, and the substitution of s.150 by section 11 of the Finance Act, 2026 (Act No. 4 of 2026), deemed made with effect from 1 February 2026, leaves those words untouched while splitting the sub-section into clause (a) for an authority and clause (b) for a court. One change is worth marking. Clause (b) now reaches “a court in any proceeding under this Act or any other law”, where the earlier text reached a court only in a proceeding under some other law. This decision says nothing about a court's order, because the 1922 proviso reached only orders under the named sections. The new s.150(3), which puts the department to a three-month period of its own, is a limit on the notice and does not touch what a finding is. On the boundary: the 1961 Act was repealed on 1 April 2026 by s.536(1) of the Income-tax Act, 2025 and continued by s.536(2) for tax years beginning before that date, so s.150 and this construction still govern those years. For later years the provision is s.283 of the 2025 Act, which carries the same expression. No source could be cited for that finding. Checking whether an authority still stands matters as much as knowing what it held: a decision may be overruled on one point and survive on another, or the provision it interprets may have been amended since. Read the source and the editor's note on this page before relying on it in a reply to an Assessing Officer or in an appeal.
The judgment was read in full on its own record and then on a second, separately published reproduction; the two agree on the coram, on the sentences quoted here and on the order. The respondent's name is spelt “Murlitdhar Bhagwandas” in the record of the appeal; the case is universally cited as Income-tax Officer v Murlidhar Bhagwan Das, and that is the form used here. The citations AIR 1965 SC 342 and [1964] 6 SCR 411 are printed with the judgment. The report at [1964] 52 ITR 335 is taken from citation strings printed inside later judgments that cite it, including Rajinder Nath, and not from any editorial source. The composition matters and is easy to get wrong. Five judges sat. The majority opinion is given by Subba Rao J for himself and on behalf of Sinha CJ and Rajagopala Ayyangar J, and the dissent by Mudholkar J for himself and on behalf of Raghubar Dayal J, so the split is three to two. Subba Rao J's own opinion closes “In this view no other question arises for our consideration. In the result, the appeal fails and is dismissed with costs”, and the order at the foot of the judgment records “In view of the judgment of the majority, the appeal fails and is dismissed with costs”. Both forms are given because both are in the judgment. Two sentences that circulate as this Court's are not. The first is the definition of “finding”. It is the Allahabad High Court's, from Pt. Hazari Lal v Income-tax Officer, Kanpur, which the majority set out and then met with “We agree with this definition of ‘finding’.” This entry therefore quotes the Court's own gloss, the sentence that follows the agreement. The second is the proposition that the proviso does not save the time limit for a year other than the year that is the subject matter of appeal or revision. That sentence is the reporter's, from the summary printed above the judgment in the Supreme Court Reports, and it appears in neither opinion; the second reproduction, which prints no such summary, does not carry it at all. What the majority itself says is quoted in the holding above. The holding has been checked against two later Supreme Court judgments read separately, Banwari Lal Agarwal of 18 January 1971 and Rajinder Nath of 13 August 1979, both of which restate it and the second of which applies it to the 1961 Act. Section 31 of the 1922 Act, on which the majority relies for the limits of the appellate power, is discussed in the prose but not carried as a section label, because a bare “31” would point to a different Act's section of that number. The Court did not decide what happens where the appellate authority does in fact have power over the other year or the other person — it held only that s.31 gave the Appellate Assistant Commissioner no such power over a year not before him. It did not fix the outer edge of “intimately connected”, so how far a finding can reach into a related assessee's assessment is left at large. It says nothing about an order of a court, which the 1922 proviso did not cover and s.150(1) now does. And it could not address s.150(2), which had no counterpart in the 1922 Act: the second bar, on a year already dead when the order under appeal was made, comes from a later statute and a later decision. This library shows the verification state of every entry openly. This entry has not yet been read in full by a chartered accountant. The summary reflects the sources listed on this page. Read the source before you rely on it in a reply to an Assessing Officer or in an appeal before the Commissioner (Appeals) or the Income Tax Appellate Tribunal.
The appeal was dismissed. The question the Court framed for itself was whether the second proviso to s.34(3) saves the time limit in s.34(1) in respect of an escaped assessment of a year other than the year that is the subject matter of the appeal or revision, and the majority answered it in the negative: “In the result, we hold that the said provision would not save the time-limit prescribed under sub-s. (1) of s. 34 of the Act in respect of an escaped assessment of a year other than that which is the subject-matter of the appeal or the revision.” Three things were decided on the way there. On “finding”, the majority took the definition the Allahabad High Court had given in Pt. Hazari Lal, agreed with it, and put its own gloss on it: “A ‘finding’, therefore, can be only that which is necessary for the disposal of an appeal in respect of an assessment of a particular year.” On “direction”, it held that the word “cannot be construed in vacuum, but must be collated to the directions which the Appellate Assistant Commissioner can give under s. 31”, and that of that section “no power is conferred on him to make an order or issue directions in respect of an assessment of a year which was not the subject-matter of the appeal”. On “any person”, it held that the expression “must be confined to a person intimately connected in the aforesaid sense with the assessment of the year under appeal”. Raghubar Dayal and Mudholkar JJ dissented, Mudholkar J taking the view that a conclusion need not be final or ultimate to be a finding. The Court's order records: “In view of the judgment of the majority, the appeal fails and is dismissed with costs.”
TaxSphere, “ITO v Murlidhar Bhagwan Das — a finding is only what the year under appeal actually required”, https://taxnotice.vittsphere.com/caselaw/case/ito-v-murlidhar-bhagwan-das-what-a-finding-or-direction-means/ (validity last checked 2026-09-23)
The judgment itself is a government work and may be quoted freely. The summary, the validity note and the reasoning on this page are this library's own writing: quote them with attribution, and please do not present either as the words of the court — this page keeps the two apart and so should a quotation of it.
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The officer says a court's order in my land acquisition case lets him reopen years going back to the sixties, because s.150(1) says the notice may be issued at any time. Can he?
The officer has reopened a very old year and says he is only giving effect to a finding in an appellate order, so limitation does not apply. Is that right, and what stops him?
A fixed deposit stands in the name of a partner's son and my firm used it as security for its overdraft. The Assessing Officer says the money is really the firm's concealed income. Who has to prove what?
My business income was estimated on a percentage of turnover because my books were rejected. Can unexplained credits in those same books still be added separately as income from undisclosed sources?
