Court Rules Amendment to Section 40 Cannot Retroactively Impose Liability on Time-Barred Tax Re-assessments.

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....Whether the re-assessment proceedings initiated against the petitioner are barred by limitation? - The amendment made to Section 40 of the Act, cannot be construed so as to open up a liability which had become barred. Even by retrospective operation of law, the aforesaid vested right accrued to the petitioner cannot be taken away - the re-assessment proceedings for the period between April 2006 to December 2006 and April 2007 to December 2007 is held to be barred by limitation. - HC....