Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2006 (1) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2006 (1) TMI 110 - HC - Income TaxReopening of the assessment u/s 148 r.w.s. 150 – limitation - held that the plain language of sub-section (2) of section 150 clearly restricts the application of sub-section (1) to enable the authorities to reopen assessments which have not already become final on the expiry of the period of limitation prescribed under section 149 - held that the provisions of section 150(1) as amended with effect from April 1, 1989, did not enable the authorities to reopen assessments, which had become final due to the bar of limitation prior to April 1, 1989, - proceedings which had attained finality under existing law due to bar of limitation cannot be held to be reopened for revival unless the amended provision is clearly given retrospective operation so as to allow upsetting of proceedings which had already concluded and attained finality.
|