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Issues:
1. Validity of assessment notices issued beyond the prescribed time limit under the Agrl. I.T. Act. 2. Jurisdictional authority of the revision Board to annul and modify assessments. Analysis: 1. The judgment pertains to the issuance of assessment notices by the Collector to certain individuals under the Agrl. I.T. Act for the years 1359 Fasli, 1360 Fasli, 1361 Fasli, and 1363 Fasli, which were found to be beyond the permissible time limit of three years as per Section 25 of the Act. The Board contended that the notices were justified due to pending partition proceedings in the family. However, the High Court ruled that assessment proceedings for individuals cannot be considered a continuation of family partition litigation, emphasizing the distinct assessable entities of individuals and Hindu Undivided Families (HUFs). The Court held that the notices issued on November 6, 1965, were without jurisdiction as they violated the mandatory condition of timely notice issuance under Section 15(3) of the Act, rendering the proceedings invalid. 2. Regarding the second issue raised by the assessee concerning the revision Board's authority to annul and make fresh assessments on legal heirs, the Court did not provide a specific answer as the first question was answered in favor of the assessee. The judgment highlighted the importance of complying with statutory provisions and the delineation between individual and HUF assessments under the Agrl. I.T. Act. The Court awarded costs to the assessee and concluded the judgment by returning the second question unanswered due to the resolution of the first issue in favor of the assessee.
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