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    <title>2004 (5) TMI 565 - ALLAHABAD HIGH COURT</title>
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    <description>A retrospective amendment to the U.P. Sales Tax limitation provision was held to govern pending reassessment proceedings, so expiry of the earlier limitation period did not defeat the reassessment. The later binding Supreme Court interpretation was treated as controlling and displaced the contrary time-bar argument. On rectification, section 22 could not be used to reopen the Tribunal&#039;s order once the issue had merged in the High Court judgment and the proceeding had otherwise lost utility with lapse of time. Rectification was therefore not maintainable in the circumstances and had become infructuous.</description>
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    <pubDate>Mon, 17 May 2004 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=163457</link>
      <description>A retrospective amendment to the U.P. Sales Tax limitation provision was held to govern pending reassessment proceedings, so expiry of the earlier limitation period did not defeat the reassessment. The later binding Supreme Court interpretation was treated as controlling and displaced the contrary time-bar argument. On rectification, section 22 could not be used to reopen the Tribunal&#039;s order once the issue had merged in the High Court judgment and the proceeding had otherwise lost utility with lapse of time. Rectification was therefore not maintainable in the circumstances and had become infructuous.</description>
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      <pubDate>Mon, 17 May 2004 00:00:00 +0530</pubDate>
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