Dismissing the appeal of the Revenue the Tribunal held that the amendment made by the Finance Act, 2012 to section 149 by the introduction of section 149(1)(c) which extends the period of reopening assessment where income in relation to any asset located outside India chargeable to tax has escaped assessment to 16 years, came into effect from 1-7-2012 has to be applied prospectively. Order of CIT(A) was affirmed. (AY. 1999-2000)
DCIT v. Indira D. Thakkar (Smt.) (2022) 195 ITD 40 / 217 TTJ 569 / 213 DTR 369 (Mum.)(Trib.)
S. 149 : Reassessment-Time limit for notice-Foreign assets-Amendment to section 149 by Finance Act, 2012 with effect from 1-7-2012, which extended limitation for reopening assessment in case of income from foreign assets to sixteen years, is prospective in nature. [S. 147, 148, 149(1)(c)]