Reassessment proceedings could not be initiated after expiry of four years

IT : Reassessment proceedings could not be initiated after expiry of four years from relevant assessment year merely on ground that in view of retrospective amendment to provisions of section 80-IA, assessee was not entitled to deduction granted under said section earlier
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[2014] 51 taxmann.com 369 (SC)
SUPREME COURT OF INDIA
Commissioner of Income-tax
v.
Avadh Transformers (P.) Ltd.*
R. M. LODHA AND KURIAN JOSEPH, JJ.
SPECIAL LEAVE TO APPEAL (CIVIL) NO. 21477 OF 2013†
APRIL  11, 2014
Section 80-IA, read with section 147 of the Income-tax Act, 1961 - Deductions - Profit and gains from infrastructure undertaking (Reassessment) - Assessment year 2006-07 - High Court by impugned order held that reassessment proceedings could not be initiated after expiry of four years from relevant assessment year merely on ground that in view of retrospective amendment to provisions of section 80-IA, assessee was not entitled to deduction granted under said section earlier - Whether Special Leave Petition filed against impugned order was to be dismissed - Held, yes [In favour of assessee]
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