( 1 ) THE facts found and/or admitted in these proceedings, inter alia, are as follows : b. R. Vasa, the assessee, had been assessed to income-tax in the assessment year 1947-48, the relevant previous year being the one ended on the 31st March, 1947. Subsequently, on the 29th February, 1964, it was found that in the said year the assessee had made deposits totalling Rs. 56,996 in an account with the United Bank of India at Bombay which had not been disclosed by the assessee in his return. With the approval of the CBDT, on the 29th March, 1964, a notice under Section 147 of the I. T. Act, 1961, was issued and served on the assessee. Explanations given by the assessee in reassessment proceedings were rejected and the said deposits were added to his total income and brought to tax.

( 2 ) BEING aggrieved, the assessee preferred an appeal before the AAC, who confirmed the reassessment. The assessee preferred a further appeal to the Tribunal. It was contended before the Tribunal for the first time that the reassessment proceedings under Section 34 of the Indian I. T. Act, 1922, had become time-barred on the 31st March, 1962, in the instant case and could not have been validly i