Doctrine of limitation prevents revival of lapsed reassessment powers; administrative instructions cannot "travel back in time."

The court held that when the right to reopen assessment had already lapsed under the pre amended limitation regime, subsequent amendments or administrative instructions could not revive that right; administrative attempts to "travel back in time" and extend limitation were invalid, assessees retain the defence of limitation, and pandemic era notifications did not cover years whose limitation had already expired.

---

---

---