J.P. Jani, Income-Tax Officer, Circle ... vs Induprasad Devshankar Bhatt on 20 August, 1968
The Bench followed the decisions in S.S. Gadgil v. Lal and Co. [1964] 53 ITR 231 (SC) ; AIR 1965 SC 171 and J.P. Jani, Income-tax Officer v. Induprasad Devshanker Bhatt [1969] 72 ITR 595 (SC) ; AIR 1969 SC 778 and held that "by that time, as mentioned earlier, by applying the three years rule period for completing assessment was already over. Subsequent amendment cannot give the power of assessment to the officer in respect of an year for which the assessment has already become barred".