The petitioner challenged notices issued under S. 148 on the ground that cl. (c) of s. 149(1), inserted w.e.f. 1-7-2012, could not be applied retrospectively. The Court noted that the Explanation to s. 149 inserted by the Finance Act, 2012 expressly clarified that the amended provisions of sub-ss. (1) and (3) would apply to “any assessment year” beginning on or before 1-4-2012. The expression “any” was held to be of wide import and not restrictive. The Court further observed that S. 147 was simultaneously amended by insertion of Expln. 4 and that the legislative intent, as reflected in the Notes on Clauses to the Finance Bill, 2012, indicated applicability to earlier assessment years. The earlier decision in Brahm Datt v. Asstt. CIT ((2019) 306 CTR 114(Delhi) (HC) had not considered the impact of the Explanation to S. 149 or Expln. 4 to s. 147, nor the Notes on Clauses. Reference was also made to Addl. CST (Legal) v. Jyoti Traders (1999) 2 SCC 77/ (1999) 152 CTR 177 (SC)  on principles of statutory interpretation. In view of the apparent conflict and the need for authoritative pronouncement, the matter was directed to be placed before the Chief Justice for constitution of a Larger Bench. (AY.. 1997-98 to 2005-06)