“ 13. In K. M. Sharma's case (supra) the assessee's land was acquired under the Land Acquisition Act, 1894 and an award was passed in 1967 granting compensation in favour of the assessee. Thereafter, the Additional District Judge by judgment dated May 20, 1980, held the assessee to be entitled to 1/32nd share of the compensation and the assessee was granted total compensation of Rs. 1,18,810 in the year 1981. Subsequently, by another judgment dated July 31, 1991, the assessee was awarded a sum of Rs. 1,10,20,624, which was received by it between October 15, 1992 and May 25, 1993. The said amount comprised of principal compensation as well as interest up to May 18, 1992. As land acquired was agricultural land, principal amount was not chargeable to tax ; however, interest amounting to Rs. 76,84,829 was chargeable on year to year basis. The assessee claimed that proceedings till assessment year 1982-83 had already attained finality and therefore, filed a letter requesting the Assessing Officer to initiate proceedings for subsequent assessment years for bringing to tax interest component relatable to the said assessment years. The assessee was, however, issued notices under section 148 of the Act for fifteen assessment years, viz., assessment years 1968-69 to 1971-72 and assessment years 198182 to 1992-93 which were challenged on the ground of limitation. This court declined to exercise jurisdiction ; on appeal, the Supreme Court held that the provision regulating period of limitation ought to receive strict construction. The Supreme Court held that the law of limitation was intended to give certainty and finality to legal proceedings and therefore, proceedings, which had attained finality under the existing law due to bar of limitation, could not be held to be open for revival unless the amended provision was clearly given retrospective operation so as to allow upsetting of proceedings, which had already been completed and attained finality…..
