1996 (4) TMI 481

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... assessment year 1981-82. The original assessment against the petitioner was completed on June 13, 1984. Subsequently, pursuant to certain seizures in relation to the business transactions of the petitioner, it was subjected to reassessment proceeding which culminated in a reassessment order dated December 28, 1988. The only question raised on behalf of the petitioner is that keeping in view the p .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... at the assessment as made on December 28, 1988 is well within the period of limitation as per the provision of section 12A as it stood at the time of passing of the said order. But the contention of Sri B.P. Gandhi, learned counsel appearing for the petitioner is that the limitation should be computed keeping in view the law either as it existed at the time of filing of the return or as it existed .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... to the assessee, the existing period of limitation may be enlarged by legislation. But once there is immunity, unless the Legislature amends the law retrospectively or declares any provision as applicable to the concluded proceedings also by clear and specific words, it is not possible to read into those provisions a power enabling the assessing authorities to undo what has become final." 5.. In .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X