https://www.taxtmi.com/caselaws?id=166488 An amendment deeming inclusion in a partner's assessment, based on a later firm assessment, to be a rectification of mistake and shifting the limitation point was treated as prospective where vested rights were affected. The unamended law did not permit reopening a final assessment on the basis of facts emerging from a later firm assessment, because that was not a mistake apparent from the record. The deeming date in section 1(2) was not read to enlarge the retrospective reach of the amendment, and the wider reopening provisions elsewhere in the Act showed that broader retrospective operation was not intended. Rectification orders against final assessments made before 1 April 1952 were therefore without jurisdiction. en-us Fri, 09 Dec 1955 00:00:00 +0530 Mon, 29 Sep 2014 10:55:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=166488 An amendment deeming inclusion in a partner's assessment, based on a later firm assessment, to be a rectification of mistake and shifting the limitation point was treated as prospective where vested rights were affected. The unamended law did not permit reopening a final assessment on the basis of facts emerging from a later firm assessment, because that was not a mistake apparent from the record. The deeming date in section 1(2) was not read to enlarge the retrospective reach of the amendment, and the wider reopening provisions elsewhere in the Act showed that broader retrospective operation was not intended. Rectification orders against final assessments made before 1 April 1952 were therefore without jurisdiction. Case-Laws Income Tax Fri, 09 Dec 1955 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=166488