https://www.taxtmi.com/caselaws?id=186862 An amended reopening proviso under the Income-tax Act was treated as unable to revive a reassessment remedy already barred by limitation, because the time limit formed part of the statutory competence to reopen an assessment and no clear intention to validate a time-barred notice was expressed. The notice issued after expiry of the original period was therefore incompetent and invalid. On constitutional challenge, the limitation exception was upheld for assessees who were parties to the specified appellate or revisional proceedings, but held discriminatory and unconstitutional insofar as it denied limitation protection to strangers to those proceedings under article 14. en-us Wed, 05 Oct 1955 00:00:00 +0530 Mon, 03 Oct 2016 14:32:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=186862 An amended reopening proviso under the Income-tax Act was treated as unable to revive a reassessment remedy already barred by limitation, because the time limit formed part of the statutory competence to reopen an assessment and no clear intention to validate a time-barred notice was expressed. The notice issued after expiry of the original period was therefore incompetent and invalid. On constitutional challenge, the limitation exception was upheld for assessees who were parties to the specified appellate or revisional proceedings, but held discriminatory and unconstitutional insofar as it denied limitation protection to strangers to those proceedings under article 14. Case-Laws Income Tax Wed, 05 Oct 1955 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=186862