Reassessment notice must follow the amended Section 148A procedure after 01.04.2021, or it cannot confer jurisdiction.

Reassessment notices issued under Section 148 after 01.04.2021 had to comply with the substituted procedure introduced by the Finance Act, 2021, including Section 148A and the amended reassessment framework. In the absence of any saving clause preserving the earlier regime for post-substitution notices, failure to follow the new statutory requirements meant the notice could not validly confer jurisdiction for reassessment. The Section 148 notice was therefore held unsustainable and was quashed.

---

---

Issues: Whether the reassessment notice issued under Section 148 of the Income-tax Act, 1961, after 01.04.2021, could stand without compliance with the substituted reassessment procedure introduced by the Finance Act, 2021.

Analysis: The reassessment regime was held to have been substituted with effect from 01.04.2021, including the insertion of Section 148A and corresponding changes to the reassessment provisions. In the absence of any saving clause preserving the earlier law for notices issued after the substitution, the notice had to conform to the amended procedure. A notice issued without following the new statutory requirements could not validly assume jurisdiction for reassessment.

Conclusion: The notice under Section 148 was unsustainable and was quashed.

---