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    <title>2009 (7) TMI 1174 - PUNJAB AND HARYANA HIGH COURT</title>
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    <description>Assessment proceedings that had already become time-barred under the unamended limitation period could not be revived by a later amendment extending the assessment period, because the amendment was not shown to operate retrospectively so as to restore an extinguished power. The settled principle applied was that an assessee acquires a vested right not to be proceeded against once the statutory limitation expires, and a subsequent amendment cannot reopen a time-barred assessment unless the statute clearly so provides. The special validating provision was confined to its expressly covered class and period and did not authorise the impugned assessments, so the assessments and consequential demands were quashed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=164530</link>
      <description>Assessment proceedings that had already become time-barred under the unamended limitation period could not be revived by a later amendment extending the assessment period, because the amendment was not shown to operate retrospectively so as to restore an extinguished power. The settled principle applied was that an assessee acquires a vested right not to be proceeded against once the statutory limitation expires, and a subsequent amendment cannot reopen a time-barred assessment unless the statute clearly so provides. The special validating provision was confined to its expressly covered class and period and did not authorise the impugned assessments, so the assessments and consequential demands were quashed.</description>
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