Extension of time for Special audit by AO on Suo moto basis

CIT Vs. Ram Kishan Dass (Supreme Court) Facts of the case Revenue is in appeal against Delhi High Court order holding that proviso to section 142(2C) authorizing AO to extend the time limit suo moto w.e.f. 01-04-2008 is prospective in nature and therefore AO can extend time for special audit on application of assessee and not on suo moto basis for periods prior to 01-04-2008. Arguments by Assessee As per memorandum explaining provisions of Finance bill and notes on clauses the amendment is prospective[Para 10 to 11A] Amendment is not procedural because The consequence of the exercise of the j...