Constitutional Boundaries of Delegated Legislation in Direct Tax Assessments
Published:
August 02, 2026
10 min read
A constitutional study on CBDT circulars, reassessment limitation periods, and the doctrine of ultra vires in fiscal notifications.
High Courts across India have repeatedly struck down executive notifications attempting to retrospectively extend limitation periods for reopening past income tax assessments. This treatise analyses the constitutional limits placed on executive rulemaking under Article 265 of the Constitution of India.
Ananya Roy Choudhury
Partner & Head of Dispute Resolution • New Delhi
Ananya Roy Choudhury leads the Dispute Resolution & International Arbitration practice at Vertex Legal LLP. She has an illustrious reputatio...