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2007 (4) TMI 353 - SC - VAT and Sales Tax
Nature of the amendment - whether it is at all retrospective in operation, and if not, whether the provision as amended by the Second Amendment applies to the appellant?
Held that:- Appeal allowed. Undisputedly, the 1996 circular was binding on the revenue authorities as is spelt out in the case of April 12, 1996 and October 23, 1999 circulars. The assessments were completed on the basis of the April 12, 1996 circular. Merely because the Commissioner changes his view/opinion and according to him it was review of the earlier decision that cannot have any effect on any assessment which has been completed on the basis of the 1996 circular. That being so, the question of reopening the assessment by mere change of opinion is entirely impermissible