Reassessment notices after statutory substitution must follow the new procedure; old-regime extensions were held ultra vires and invalid.

The substituted reassessment procedure under Sections 147 to 151 of the Income-tax Act, 1961 operated from 1 April 2021, so notices issued after 31 March 2021 had to follow the new statutory mechanism; notices issued under the old regime were invalid. The relaxation statute empowered extension of time limits only, not continuation of the earlier reassessment procedure or alteration of the substantive initiation framework, so the notifications and their explanations were ultra vires and void. As the impugned notices were issued under an inapplicable and invalid regime, they could not be sustained and were quashed.

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Issues: (i) Whether reassessment notices issued after 31 March 2021 without following the substituted procedure under Sections 147 to 151 of the Income-tax Act, 1961 were valid; (ii) Whether the notifications and their explanations extending the old reassessment regime beyond 31 March 2021 were within the power conferred by the relaxation statute; (iii) Whether the impugned reassessment notices were liable to be quashed.

Issue (i): Whether reassessment notices issued after 31 March 2021 without following the substituted procedure under Sections 147 to 151 of the Income-tax Act, 1961 were valid.

Analysis: The substituted reassessment scheme introduced by the Finance Act, 2021 operated from 1 April 2021. Notices issued after 31 March 2021 had to conform to the new procedure, and the continued use of the earlier regime was inconsistent with the legislative change.

Conclusion: The notices issued after 31 March 2021 without following the substituted procedure were invalid.

Issue (ii): Whether the notifications and their explanations extending the old reassessment regime beyond 31 March 2021 were within the power conferred by the relaxation statute.

Analysis: The power under the relaxation statute was confined to extending time limits. It did not authorise alteration of the substantive procedure for initiation of reassessment proceedings or permit the old provisions to continue beyond their statutory sunset. The impugned explanations were therefore inconsistent with the parent statute and ineffective to postpone the operation of the substituted provisions.

Conclusion: The notifications and their explanations were ultra vires the relaxation statute and void.

Issue (iii): Whether the impugned reassessment notices were liable to be quashed.

Analysis: Once the notices were found to have been issued under an inapplicable and invalid procedural regime, they could not be sustained in law.

Conclusion: The reassessment notices were quashed.

Final Conclusion: The writ petitions succeeded because the reassessment notices were issued under an impermissible continuation of the old regime, and the executive notifications could not override the substituted statutory framework.

Ratio Decidendi: When Parliament substitutes the reassessment procedure with effect from a specified date, delegated notifications cannot extend the earlier procedure beyond that date or dilute the mandatory statutory mechanism for issuing notices.

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