HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
First Additional Income-tax Officer, Mysore v. H.N.S. Iyengar
Civil Appeal No. 60 of 1961
[1962] Supp 1 SCR 1 ·
Indian Income-tax Act, 1922: sections 22(1) and 34(1)(a) · Indian Finance Act, 1948
Sources & disclosures includedDownload original judgment / order
3-judge bench; unanimous judgment delivered by J. L. Kapur, J. · S. K. Das, J. · J. L. Kapur, J. · M. Hidayatullah, J.
Assessment years: 1949-50
01 · Facts of the case
A November 1956 notice sought a return for income assessable for the year ending 31 March 1949. The assessee argued that eight years ran from the end of the accounting year; the Mysore High Court accepted that view and quashed the proceeding (SCR pp.1-3; PDF pp.1-3).
Source: Primary judgment: facts
02 · Discussion by the Hon’ble Court
A return under section 22 is for an assessment year although it reports previous-year income. Different income heads may use different previous years, making the assessment year the coherent limitation anchor. The phrase “for any year” in section 34(1)(a) therefore referred to the assessment year (SCR pp.4-7; PDF pp.4-7).
Source: Primary judgment: discussion
03 · Judicial decision
The Court set aside the High Court's order, restored the proceeding and awarded Revenue costs in both courts (SCR p.7; PDF p.7).
Source: Primary judgment: decision
04 · Outcome / in whose favour
In favour of Revenue: the reassessment notice was not barred on the accounting-year theory (SCR pp.6-7; PDF pp.6-7).
Source: Primary judgment: outcome
05 · AKHB REVIEW POINT
AKHB analysis: determine the statute's chosen limitation unit before counting time. This historical assessment-year interpretation cannot replace the notice-specific clocks, transition rules and extensions in current reassessment law (based on SCR pp.5-7; PDF pp.5-7).
Source: Primary judgment: review point
Source & verification
Download original judgment / order · Open cited source rendition
Full 7-page SCR source asset read in page-preserving text and visually inspected; adjacent-report boundaries were checked.
- Exact source bytes, SHA-256 and seven-page count match catalogue asset S_1962_1_1_7; every page was read and visually inspected.
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Statutory scope
The limitation ruling applies section 34 of the repealed 1922 Act and the 1948 Finance Act; current reassessment law was not examined.
Later treatment
Source checked 2026-10-11. Later judicial treatment and current statutory applicability have not been comprehensively checked; no current-law or citator clearance is represented.
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