The Calcutta High Court ruled that all reassessment proceedings post-September 1, 2024, must adhere to the amended provisions of Section 149 of the Income Tax Act. This decision reaffirms a Supreme Court verdict, establishing the retrospective application of the new limitation period.
Calcutta HC's Ruling on Retrospective Limitation Period
The Calcutta High Court has ruled that the amended limitation period under Section 149 of the Income Tax Act applies retrospectively. This decision indicates that all reassessment proceedings initiated after September 1, 2024, must conform to the newly established time limits stipulated in the amended provision.
In arriving at this decision, the court relied on a significant precedent set by the Supreme Court that affirmed the retrospective nature of such amendments. The ruling clarifies that the reassessment process must follow the procedural timeline laid out in the amended legislation, thus nullifying any reassessments that do not comply with these provisions.
This decision has substantial implications for tax practitioners. They must ensure that any ongoing or future reassessment proceedings are compliant with the amended Section 149, taking note of the specified dates to avoid jeopardizing the legal standing of such proceedings.
Citations
- Calcutta HC (2026) Tax Reporter Page
