Reopening U/s. 147 even within 4 years, on basis of retrospective amendment invalid

Ganesh Housing Corporation Ltd Vs. DCIT (Gujarat High Court) Main reason for opening the assessment is that in the light of the Explanation inserted to Section 80-1B (10) by the Finance Act (No. 2), Act 2009 with retrospective effect from 01.04.2000, deduction u/s 801B (1 0) shall not be admissible to a contractor in respect of works contract awarded by any person. Assessing Officer has on the basis of the materials originally placed by Assessee held that the Assessing Officer in the assessment proceedings u/s 143(3) did not give any opinion regarding the allowability or otherwise of deduction...