M/S. Eagle Traders & Logistics, Bellary vs. Deputy Commissioner of Income Tax, Central Circle- 2(3), Bangalore
Accordingly, the appeals filed by the assessee are allowed in above terms
ITA 237/BANG/2020[2011-12]Status: DisposedITAT Bangalore29 May 2025AY 2011-12
Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey
For Appellant: Shri. Prashanth G S, CAFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 132(1)(a)Section 132(2)Section 153ASection 153CSection 153DSection 292B
…substantive rights and amendments affecting such rights have been held to be prospective. That reopening has been held to be a question of power and not procedure as observed and held by this Court in the case of State of Tamil Nadu v. Star Tobacco Co. [1974] 3 SCC 249. 5.6 It is next contended that the amendment to section 153C of the Act, 1961 has added a new class of assessees and not merely changed the procedure for the existing assessees, hence it cannot be given retrospective effect. That the High Court has specifically observed and held that the amendment to section 153C of the Act, 1961 is not merely a ch…