https://www.taxtmi.com/caselaws?id=49428 Section 35(5) was held to have only limited retrospectivity from the operative date and cannot reopen assessments finally completed before that date; accordingly attempts to reopen pre-operative final assessments under that provision fail. Rectification under section 35(1) requires a mistake apparent from the assessee's own record and cannot be established by reference to another assessee's (the firm's) record; raising that ground for the first time on appeal was also impermissible. Assessments were final, not provisional under the provisional-assessment regime, so reopening on that basis was unavailable. en-us Tue, 24 Apr 1962 00:00:00 +0530 Wed, 27 Aug 2014 10:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49428 Section 35(5) was held to have only limited retrospectivity from the operative date and cannot reopen assessments finally completed before that date; accordingly attempts to reopen pre-operative final assessments under that provision fail. Rectification under section 35(1) requires a mistake apparent from the assessee's own record and cannot be established by reference to another assessee's (the firm's) record; raising that ground for the first time on appeal was also impermissible. Assessments were final, not provisional under the provisional-assessment regime, so reopening on that basis was unavailable. Case-Laws Income Tax Tue, 24 Apr 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49428