2007 (2) TMI 580

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... t period April 1, 1989, to July 27, 1999. The block assessment in respect of the assessee under section 158BC of the Income-tax Act, 1961, was completed on August 31, 2001. At that time, surcharge was not levied. Subsequently, by an order dated January 7, 2003, the Assessing Officer rectified the block assessment order in exercise of powers conferred under section 154 of the Act and levied a s .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ore the Tribunal. The Tribunal held, and in our view rightly, that apart from the fact that the issue is debatable and no such order could have been passed in rectification proceedings under section 154 of the Act, even on the merits the proviso to section 113 of the Act did not have any retroactive effect. The proviso was inserted with effect from June 1, 2002, by virtue of the Finance Act, 1999, .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X