1996 (4) TMI 481

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....relates to assessment made under the Central Sales Tax Act, 1956 (in short, "the Central Act") for the assessment year 1981-82. The original assessment against the petitioner was completed on June 13, 1984. Subsequently, pursuant to certain seizures in relation to the business transactions of the petitioner, it was subjected to reassessment proceeding which culminated in a reassessment order dated....

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...., 1988, by Act 15 of 1988, it was reduced to 8 years. 3.. In the present case it is not in dispute that the assessment as made on December 28, 1988 is well within the period of limitation as per the provision of section 12A as it stood at the time of passing of the said order. But the contention of Sri B.P. Gandhi, learned counsel appearing for the petitioner is that the limitation should be co....

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....hat: "So long there is a possibility of reopening any assessment for any reason and no immunity has accrued to the assessee, the existing period of limitation may be enlarged by legislation. But once there is immunity, unless the Legislature amends the law retrospectively or declares any provision as applicable to the concluded proceedings also by clear and specific words, it is not possible to....