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    <title>1966 (2) TMI 8 - ANDHRA PRADESH High Court</title>
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    <description>A statute affecting vested rights is presumed to operate prospectively unless retrospective application is clearly expressed or necessarily implied. On that basis, proceedings for rectification and reassessment arising from completed assessments made under the Indian Income-tax Act, 1922 were held to remain governed by the 1922 Act, not the Income-tax Act, 1961. The rectification provisions of section 35(1) were unavailable because the alleged mistake was not corrected within the prescribed four-year period, and section 35(5) could not be used to reopen final individual assessments indirectly through firm-related adjustments. The limitation bar was treated as jurisdictional, so the attempted proceedings were not authorised.</description>
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    <pubDate>Wed, 23 Feb 1966 00:00:00 +0530</pubDate>
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      <title>1966 (2) TMI 8 - ANDHRA PRADESH High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=6751</link>
      <description>A statute affecting vested rights is presumed to operate prospectively unless retrospective application is clearly expressed or necessarily implied. On that basis, proceedings for rectification and reassessment arising from completed assessments made under the Indian Income-tax Act, 1922 were held to remain governed by the 1922 Act, not the Income-tax Act, 1961. The rectification provisions of section 35(1) were unavailable because the alleged mistake was not corrected within the prescribed four-year period, and section 35(5) could not be used to reopen final individual assessments indirectly through firm-related adjustments. The limitation bar was treated as jurisdictional, so the attempted proceedings were not authorised.</description>
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      <pubDate>Wed, 23 Feb 1966 00:00:00 +0530</pubDate>
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