Retrospective Tax Amendments Clarify Income Assessment Rules Under Sections 149 and 147 with Broad Interpretative Scope

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....HC held that Explanation to Section 149 and Explanation 4 to Section 147, introduced by Finance Act, 2012, clarify retrospective applicability for assessment years beginning on or before 1 April 2012. The use of word "any" in the explanation is not restrictive. The court noted that previous judicial interpretations in Brahm Datt and Jyoti Traders may require reconsideration by a larger bench. The matter was directed to be listed for constitution of a larger bench to comprehensively examine the legislative intent behind the amendments to income tax assessment provisions.....