https://www.taxtmi.com/caselaws?id=10362 Reassessment limitation under the Income-tax Act cannot be revived by the 1989 amendments to sections 147 and 149 where the relevant years were already time-barred under the earlier law. Limitation provisions in fiscal statutes are to be strictly construed, and a liability or proceeding that has attained finality under the existing law cannot be reopened unless the amending provision clearly gives retrospective effect. As the amended provisions contained no express retrospective operation, the earlier-barred reassessment notices were invalid. en-us Fri, 26 Nov 2004 00:00:00 +0530 Tue, 14 Jul 2009 11:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=10362 Reassessment limitation under the Income-tax Act cannot be revived by the 1989 amendments to sections 147 and 149 where the relevant years were already time-barred under the earlier law. Limitation provisions in fiscal statutes are to be strictly construed, and a liability or proceeding that has attained finality under the existing law cannot be reopened unless the amending provision clearly gives retrospective effect. As the amended provisions contained no express retrospective operation, the earlier-barred reassessment notices were invalid. Case-Laws Income Tax Fri, 26 Nov 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=10362