Subsequent reversal of the legal position by judgment of Supreme Court does not authorize the department to reopen the assessment

The Hon’ble Supreme Court in the case of DCIT and others Vs. Simplex Concrete Piles (India Ltd.) (2012) 254 CTR (SC) 221 at para 3 held as follows:-

“the subsequent reversal of the legal position by the judgment of Hon’ble Supreme Court does not authorize the department to reopen the assessment which stood closed on the basis of the law, as it stood at the relevant time.”

The Hon’ble Court was considering the case where, at the relevant time when the assessment order go

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