Allowing the appeal of the Revenue the Tribunal held that Explanation to section 149 unambiguously provides that provisions of sub-sections (1) and (3), as amended by Finance Act, 2012, shall also be applicable for any assessment year beginning on or before 1-4-2012. Accordingly the amendment to section 149(1) providing longer time limit of 16 years for reopening assessments in foreign asset cases is expressly stated to be retrospective in nature, and there is no bar on validity of retrospectively of taxing statute as long as it is clearly specified to be so. (AY. 1999-2000)