EMPIRE STORES vs INCOME TAX OFFICER

The Supreme Court held that the change in law regarding the period of limitation does not have retrospective application, thus the authority cannot rely on the larger period prescribed under the new law for reassessment. The Court emphasized that the petitioner must first present their case before the assessing authority regarding the applicability of the limitation period. The dismissal of the special leave petition indicates that the petitioner retains the right to contest the issue of limitation in subsequent proceedings.