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    <title>1995 (9) TMI 362 - ALLAHABAD HIGH COURT</title>
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    <description>A reassessment that had already become time-barred could not be revived by a later amendment to the U.P. Trade Tax Act, because expiry of limitation created a vested protection against reopening and the amended proviso could not operate retrospectively to confer jurisdiction. The writ remedy under Article 226 was also treated as maintainable despite an alternative appellate remedy, where the assessee showed that the departmental forum would not independently apply the law already declared and the remedy was therefore not effective. The commentary&#039;s central principle is that a subsequent amendment cannot reopen a closed proceeding once limitation has expired.</description>
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      <link>https://www.taxtmi.com/caselaws?id=158986</link>
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