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    <description>Substituted limitation provisions under section 21(2) of the U.P. Trade Tax Act governed pending assessment and reassessment proceedings. The amended regime introduced by U.P. Act No. 11 of 1997 prescribed an outer date up to which assessments could be completed, replacing the earlier limitation framework. Where the amendment is valid and its validity is not challenged, pending assessments must be tested under the substituted provision rather than the former period. The amendment was treated as a new statutory prescription, not as revival of an extinguished limitation right, with the effect that assessments completed within the extended period were not time-barred.</description>
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