https://www.taxtmi.com/caselaws?id=190276 The Court did not decide the substantive validity of the reassessment notice on merits. It held that the objection that the amended law enlarging the limitation period cannot apply retrospectively raises mixed questions of fact and law, which must first be examined by the assessing authority. The petitioner was directed to raise the limitation plea before that authority, and, if necessary, in appeal. The Court observed that the longer limitation period may already be attracted on certain factual scenarios under the prior law, so the question of prospective or retrospective operation depends on factual findings. The special leave petition was dismissed, leaving the issue open for determination on facts. en-us Fri, 02 Apr 1993 00:00:00 +0530 Fri, 10 Feb 2017 16:44:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=190276 The Court did not decide the substantive validity of the reassessment notice on merits. It held that the objection that the amended law enlarging the limitation period cannot apply retrospectively raises mixed questions of fact and law, which must first be examined by the assessing authority. The petitioner was directed to raise the limitation plea before that authority, and, if necessary, in appeal. The Court observed that the longer limitation period may already be attracted on certain factual scenarios under the prior law, so the question of prospective or retrospective operation depends on factual findings. The special leave petition was dismissed, leaving the issue open for determination on facts. Case-Laws Income Tax Fri, 02 Apr 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=190276