Reassessment challenge under sections 148 and 148A: constitutional validity of notifications and reopening notice stayed with ad-interim relief.

The petition challenged the constitutional validity and vires of the explanations in Notifications No. 20/2021 and 38/2021, questioned the applicability of the amended reassessment regime under sections 148 and 148A of the Income-tax Act, 1961, and assailed the notice issued under section 148 for reopening assessment. The HC issued notice to the respondents, directed completion of pleadings, and granted ad-interim relief in terms of paragraph 10(f) until the returnable date.

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Issues: Challenge to the constitutional validity and vires of the explanations in Notification No. 20/2021 dated 31.03.2021 and Notification No. 38/2021 dated 27.04.2021, the applicability of the amended reassessment provisions under sections 148 and 148A of the Income-tax Act, 1961, and the validity of the notice issued under section 148 for reopening assessment.

Outcome: Notice issued to the respondents returnable on 03.01.2022, pleadings were directed to be completed, and ad-interim relief was granted in terms of paragraph 10(f) till the returnable date.

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