1993 (4) TMI 317

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..... rely on the larger period of limitation prescribed under the new law. On this basis he submits that in the present case the notice of reassessment given to the petitioner is invalid because it is based on the application of the larger period of limitation prescribed under the new law. The High Court has dismissed the petitioner s writ petition on the ground that the points raised by the petitioner .....

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..... s of facts on which he claims that the benefit of the larger period of limitation under the old law is not available in the present case to reopen the assessment for the assessment years 1981-82 in the petitioner s case and that the larger period under the new law is not available because the same applies prospectively. This point remains open to the petitioner for being canvassed in the appropria .....

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