Court Clarifies "Relevant Assessment Year" in Section 153A, Limits Assessment Period to Six Years Per Finance Act 2017.

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....Assessment u/s 153A - “relevant assessment year” - It is not for me to fathom the wisdom of the parliament. We cannot assume that the amendment introduced by the Finance Act, 2017 intended to bring in four more years over and above the six years already provided within the scope of the provision. When the law has prescribed a particular length, it is not for the court to stretch it. Plasticity is the new mantra in neuroscience, thanks to the teachings of Norman Doidge. It implies that contrary to settled wisdom, even brain structure can be changed. But not so when it comes to a provision in a taxing statute that is free of ambiguity. Such a provision cannot be elastically construed. - HC....