S. 147 : Reassessment–Non-resident-Limitation- Offshore trust–Amendment to S. 149, by Finance Act, 2012, which extended limitation for initiation of reassessment proceedings to sixteen years, could not be resorted for reopening concluded proceedings in respect of which limitation had already expired before amendment became effective – Notice issued in 2015 for the assessment year 1998-99 was quashed. [S. 148, 149]
Brahm Datt v. ACIT (2019) 260 Taxman 380/ 173 DTR 1/ 306 CTR 114 (Delhi)(HC)