Whether the Income Tax Department can reopen tax cases from as far back as 1996, especially under the amended provisions introduced in 2012 for foreign income and assets. 🔍 Key Legal Background:Pre-2012 Rule: Tax reassessment could go back only 6 years Post-2012 Amendment (Finance Act, 2012): * The Income Tax Act was amended to allow reopening of cases up to 16 years,but only if: * There is undisclosed income related to foreign assets or bank accounts. 🏛️ Current Dispute: The assessees, including UK Paints (Overseas) Ltd, BJN Holdings (India) Ltd., and KS Dhingra, received notices to reopen old assessments from the assessment year 1997–98. They challenged the notices in Delhi High Court, saying: * The law cannot be applied retrospectively to re-open cases from so long ago. There was no specific or credible information linking them to foreign undisclosed income. ⚖️ What Delhi HC Will Decide: 1. Whether the 16-year reassessment window can be applied to cases as old as 1996–97, especially when the reassessment powers were extended only in 2012. 2. Whether the department has valid grounds or just speculative links to foreign assets. 3. What constitutes valid information for reopening such old assessments. 📌 Why This Matters: If the court allows this reopening, it could set a precedent for many such old cases. On the other hand, if the court rules against the department, it will reinforce safeguards against indefinite retrospective tax investigations Two judges heard this case But they said, “This is too big a question for just us two.” So they’re sending it to a larger group of judges to decide the matter