Limitation on reopening by Settlement Commission: applications filed after a nine-year interval cannot be reopened under section 22E. Amendment substitutes the proviso to section 22E to provide that the Settlement Commission shall not reopen any proceeding if the period between the end of the assessment year to which the proceeding relates and the date of application for settlement under section 22C exceeds nine years, thereby imposing a limitation period on the Commission's power to reopen proceedings.
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Provisions expressly mentioned in the judgment/order text.
Limitation on reopening by Settlement Commission: applications filed after a nine-year interval cannot be reopened under section 22E.
Amendment substitutes the proviso to section 22E to provide that the Settlement Commission shall not reopen any proceeding if the period between the end of the assessment year to which the proceeding relates and the date of application for settlement under section 22C exceeds nine years, thereby imposing a limitation period on the Commission's power to reopen proceedings.
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