Reassessment notice under the amended income-tax regime stayed pending challenge to transitional provisions and notifications.

The Bombay HC considered whether a reassessment notice issued under section 148 of the Income-tax Act could still be acted upon after the Finance Act, 2021 substituted the reassessment regime, and whether the challenge to section 3(1) of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and related notifications justified interim relief. The court issued notice to the respondents and the Attorney General of India, directed replies to be filed, and restrained further action on the impugned notice until the next hearing.

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Issues: Whether the notice issued under section 148 of the Income-tax Act, 1961 could be acted upon in view of the substitution of reassessment provisions by the Finance Act, 2021, and whether the challenge to section 3(1) of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and the related notifications warranted interim protection.

Outcome: Notice issued to the respondents and the Attorney General of India, reply directed to be filed, and no further action to be taken based on the impugned notice till the next date of hearing.

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