The Calcutta High Court has ruled that the amended limitation period under Section 149 of the Income Tax Act applies retrospectively to reassessment proceedings. This decision aligns with the Supreme Court’s interpretation of statutory amendments.
Retrospective Application of Limitation Period under Section 149
The Calcutta High Court has ruled that the amendments to the limitation period under Section 149 of the Income Tax Act apply retrospectively. The Court held that all reassessment proceedings initiated post-September 1, 2024, must conform to the amended provisions, ensuring that they are consistent with the statutory changes enacted.
This determination reflects the Court’s alignment with a previous Supreme Court ruling, reinforcing the importance of legislative changes and their immediate effects on reassessment processes. The judgment underscores that stakeholders in tax litigation should be aware of the impacted timelines for potential reassessment by tax authorities.
Practitioners should prepare for the broader implications of this ruling, particularly in terms of compliance with the amended timelines and proactive client advisories on potential reassessment risks within the stipulated period.
