1927 (4) TMI 4 - HC - Income Tax

Summary

The High Court of Patna ruled that a summary assessment under Section 23, Clause (4) of the Indian Income Tax Act is not valid if a notice under Section 22(4) was not issued before the filing of the return. The court found that in the case at hand, there was no breach of a notice under Section 22(4) as the notice in question may have been under a different section. Therefore, the summary assessment was deemed illegal, and the assessee was awarded costs.