https://www.taxtmi.com/caselaws?id=28273 Section 59 of the Estate Duty Act, 1953 was a substantive reassessment provision that operated only from 1 July 1960 and could not be used to reopen assessments already final before that date. In the absence of express retrospective language, a saving clause, or necessary implication authorising reopening of completed assessments, the earlier final assessment remained undisturbed. The former rectification power under section 62 was distinct from reassessment and could not support the impugned action after its deletion. Reassessment in such circumstances was therefore impermissible, and the legal position was stated against the Controller and in favour of the accountable person. en-us Mon, 28 Feb 1983 00:00:00 +0530 Sat, 20 Feb 2010 11:28:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28273 Section 59 of the Estate Duty Act, 1953 was a substantive reassessment provision that operated only from 1 July 1960 and could not be used to reopen assessments already final before that date. In the absence of express retrospective language, a saving clause, or necessary implication authorising reopening of completed assessments, the earlier final assessment remained undisturbed. The former rectification power under section 62 was distinct from reassessment and could not support the impugned action after its deletion. Reassessment in such circumstances was therefore impermissible, and the legal position was stated against the Controller and in favour of the accountable person. Case-Laws Income Tax Mon, 28 Feb 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28273