Statutory validation of pre-enactment demand notice under Finance Act provisions upheld; no substantial question of law arose.

A demand notice served before the effective date of the validating enactment was held to be covered by the statutory validation under Section 117 of the Finance Act, 2000, so the demand was treated as validated. On that basis, the challenge in the appeal could not survive and no substantial question of law was found to arise. The appeal was therefore found to be without merit.

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Issues: Whether the demand notice served on the assessee stood validated under Section 117 of the Finance Act, 2000, and whether any substantial question of law arose for consideration.

Analysis: The demand notice had been served before the effective date of the validating enactment, and the statutory validation under Section 117 was held applicable. In view of the legal position noticed, the challenge raised in the appeal did not survive, and no substantial question of law was found to arise. The appeal was therefore found to be without merit.

Conclusion: The demand was treated as validated, and the appeal failed.

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