https://www.taxtmi.com/caselaws?id=772131 The Delhi HC examined the retrospective application of amendments to Sections 147 and 149 of the Income Tax Act introduced by Finance Act, 2012, regarding reopening of assessments beyond four years. The court noted that Explanation to Section 149 and Explanation 4 to Section 147 expressly clarified their applicability to "any assessment year" beginning on or before April 1, 2012, emphasizing the non-restrictive nature of the word "any." Finding that the earlier decision in Brahm Datt case did not adequately consider these explanations and legislative intent, the court referred the matter to the Chief Justice for constitution of a larger bench for reconsideration. en-us Fri, 30 May 2025 00:00:00 +0530 Wed, 04 Jun 2025 08:40:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772131 The Delhi HC examined the retrospective application of amendments to Sections 147 and 149 of the Income Tax Act introduced by Finance Act, 2012, regarding reopening of assessments beyond four years. The court noted that Explanation to Section 149 and Explanation 4 to Section 147 expressly clarified their applicability to "any assessment year" beginning on or before April 1, 2012, emphasizing the non-restrictive nature of the word "any." Finding that the earlier decision in Brahm Datt case did not adequately consider these explanations and legislative intent, the court referred the matter to the Chief Justice for constitution of a larger bench for reconsideration. Case-Laws Income Tax Fri, 30 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772131