The assessee a non-resident. The assessee received notice u/s  148 of the Act on various dates between March 2014 and 2021  for the Assessment years 1997-98 to 1999-2000 and 2001 to 2005-06 for which  the time limits expired under section 149 as existing to prior to the amendment in 2012 on various dates prior to March 31, 2012. On writ the assessee contended that clause (c) of section 149(1) was not operative retrospectively and therefore, would be applicable only in respect of those assessment years in respect of which assessments had not been concluded. The Department contended in favour  of retrospective application of clause (c) of sub-section (1) of section 149 which clarified that provisions of sub-sections (1) and (3) od section 149 as amended by the Finance Act, 2012 were applicable for any assessment year beginning on or before April 1, 2012 ; The Court held that it was important to examine the legislative intent and the language of the statute to determine whether it was intended to be applicable retrospectively. Accordingly the matter referred to larger Bench.   (AY. 1997-98to 1999-2000, 2001to 2005-06)