Tribunal cannot consider validity of retrospective amendment

On the first blush, to say the least, in one’s conviction,there is a certain difficulty or inescapable mental block in reaily reconciling the view the HC has taken, with the applicable principles of interpretation to be gathered from case law on issues founded on any such ‘retrospective amendment of law’.In particular,the two limbs of the concluding observations,which read as under, –

“We would then be stepping out of and beyond the scope of the jurisdiction under Section 260A. The assessee too has not raised such a question in the appeal.”-

are not quite understood.

May be, prima facie,the HC’s ruling itself gives rise to a ‘substabtial question of law’; hence,one will be obliged to wait for the final outcome of the inevitable further proceedings.