Reassessment based on subsequently amended Provisions is invalid

Brahm Datt Vs ACIT (Delhi High Court) CONCLUSION – Re-assessment not tenable in law in as much as the same is barred by limitation. Any subsequent amendment in the re-assessment provisions, if not specifically mentioned, are presumed to be prospective and hence not applicable in the present case. FACTS – Petitioner, a senior citizen, was non-resident/not ordinarily resident of India from AY 1984-85 to AY 2003-04. During that period he earned income from salary and professional receipts and filed return in India in the status of non-resident/not ordinarily resident. During the search proc...