https://www.taxtmi.com/caselaws?id=10862 The newly inserted proviso to section 272A(2) of the Income-tax Act, 1961, introduced by the Finance (No. 2) Act, 1991 with effect from 1 October 1991, did not apply to a default relating to assessment year 1989-90 because no express retrospective operation was provided. Section 272A(2) was treated as a charging provision, not a merely procedural one, so it could not be applied to an earlier failure to file the return due by 30 April 1989. The Tribunal erred in applying the proviso to the pre-1991 default. en-us Thu, 23 Jan 2003 00:00:00 +0530 Mon, 27 Jul 2009 08:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=10862 The newly inserted proviso to section 272A(2) of the Income-tax Act, 1961, introduced by the Finance (No. 2) Act, 1991 with effect from 1 October 1991, did not apply to a default relating to assessment year 1989-90 because no express retrospective operation was provided. Section 272A(2) was treated as a charging provision, not a merely procedural one, so it could not be applied to an earlier failure to file the return due by 30 April 1989. The Tribunal erred in applying the proviso to the pre-1991 default. Case-Laws Income Tax Thu, 23 Jan 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=10862