https://www.taxtmi.com/caselaws?id=264112 The dominant issue was whether the amended proviso to s.21(2) UPTT, reducing the reassessment limitation from eight years to six years and adding "six years from the end of such year or March 31, 2002 whichever is later," operated retrospectively to validate a notice issued beyond six/eight years from the end of AY 1990-91. Applying that limitation provisions affecting substantive rights are not retrospective absent express words or necessary implication, SC held the March 31, 2002 date was a saving clause only for reassessments already pending within the pre-amendment eight-year regime, not to permit reopening irrespective of the assessment year. Consequently, the reassessment notice was time-barred; the HC order was set aside and reassessment initiation quashed. en-us Fri, 11 Sep 2015 00:00:00 +0530 Fri, 19 Dec 2025 12:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=264112 The dominant issue was whether the amended proviso to s.21(2) UPTT, reducing the reassessment limitation from eight years to six years and adding "six years from the end of such year or March 31, 2002 whichever is later," operated retrospectively to validate a notice issued beyond six/eight years from the end of AY 1990-91. Applying that limitation provisions affecting substantive rights are not retrospective absent express words or necessary implication, SC held the March 31, 2002 date was a saving clause only for reassessments already pending within the pre-amendment eight-year regime, not to permit reopening irrespective of the assessment year. Consequently, the reassessment notice was time-barred; the HC order was set aside and reassessment initiation quashed. Case-Laws VAT / Sales Tax Fri, 11 Sep 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=264112