Reassessment limitation cannot be revived by amendment unless retrospective effect is expressly provided.

Reassessment limitation under the Income-tax Act cannot be revived by the 1989 amendments to sections 147 and 149 where the relevant years were already time-barred under the earlier law. Limitation provisions in fiscal statutes are to be strictly construed, and a liability or proceeding that has attained finality under the existing law cannot be reopened unless the amending provision clearly gives retrospective effect. As the amended provisions contained no express retrospective operation, the earlier-barred reassessment notices were invalid.

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Issues: Whether reassessment proceedings for assessment years already barred under the unamended limitation provision of the Income-tax Act could be revived by the amended sections 147 to 149 without express retrospective operation.

Analysis: The reassessment notices were issued after the 1989 substitution of sections 147 and 149, but the right to initiate proceedings for the relevant years had already become time-barred under the earlier law. The governing principle is that limitation provisions in fiscal statutes must be strictly construed, and proceedings that have attained finality under the existing law cannot be reopened unless the amending provision is clearly made retrospective. The amended provisions did not expressly provide for retrospective effect, and the liability extinguished by limitation under the old law could not be revived by the later amendment.

Conclusion: The amended limitation scheme could not be applied to revive reassessment proceedings that had already become barred and final under the earlier law; the reassessment notices for those years were invalid.

Ratio Decidendi: A prospective amendment extending the period for reassessment does not revive assessments that had already become time-barred and attained finality under the pre-existing law, unless retrospective operation is expressly provided.

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