Reopening Tax Assessments: 10-Year Limit Not Retroactive, Stays at 6 Years as per Section 149(1) Proviso.

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....Reopening of assessment u/s 147 - Extended Period - Under no circumstances the extended period available in clause (b) of sub-section (1) of Section 149 which we may recall now stands at 10 years instead of 6 years previously available with the revenue, can be pressed in service for reopening assessments for the past period. This flows from the plain meaning of the first proviso to sub-section (1) of Section 149. - HC....