M.S.P. Rajah And Anr. vs Inspecting Assistant Commissioner Of ... on 8 February, 1971
It may also be incidentally observed that the above decision appears to have been overruled by a Full Bench of this court in I.T.R. Case No. 9 of 1968, Smt. Lucy Kockuvareed v. Commissioner of Agricultural Income-tax [1971] 82 I.T.R. 845 (Ker.) [F.B.] in which the majority took the view that the Commissioner acting under Section 34 of the Agricultural Income-tax Act must act within the period prescribed in Section 35 for making a reassessment. The reasoning in that decision appears to apply to the Appellate Tribunal also.