Retro Amendment only for companies under I-T scrutiny

Section 9 of the Retrospective Amendment to the Income Tax Act is likely to stay. But CNBC-TV18's Aakansha Sethi reports that the clause will only apply to companies that are currently under tax scrutiny. Cases that have been settled will not be reopened.

The government has been mulling various options since the amendment containing Section 9 was introduced in the Budget. The government plans keep the retrospective amendment and leave the Finance Act unchanged. However, the government passed a circular clarifying that there will be no retroactive effect to this amendment.
The difference between retroactive effect and retrospective amendment is that while a retroactive statute operates backwards in time, a retrospective statute operates forward, but looks backwards.
In layman’s terms, this essentially means that the retrospective amendment will have no retroactive effect- cases that are under scrutiny will be liable to pay tax, but with no effect of reopening the other cases. A circular to this effect had earlier been passed in April and a broader circular is likely to be passed explaining that cases that are settled will not be reopened under the Retrospective Amendment because the law of limitation does extend to the last six years. So, cases that have been settled even in the past six years will not be reopened. 
The circular could also discuss waiving of penalty and interest for companies impacted by the Retrospective Amendment.