Reassessment notice under section 148 issued after 31 March 2021 required section 148A compliance before valid initiation.

A notice under section 148 of the Income-tax Act issued after 31 March 2021 was treated as falling within the amended reassessment regime because it was communicated after that date. Compliance with section 148A was mandatory before issuing such notice, and failure to follow that procedure rendered the notice and consequential proceedings unsustainable. The notice and all resulting proceedings were quashed, with liberty to proceed afresh in accordance with law.

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Issues: Whether a notice issued under section 148 of the Income-tax Act, 1961 after 1 April 2021, without compliance with section 148A, was sustainable in law and whether the consequential proceedings could stand.

Analysis: The notice was treated as having been issued on the date of its communication, which was after 31 March 2021. The matter therefore fell within the amended reassessment regime. Under that regime, compliance with section 148A was mandatory before issuing notice under section 148. As that procedure had not been followed, the notice and the subsequent proceedings were not legally sustainable.

Conclusion: The notice under section 148 and all consequential proceedings were quashed, with liberty to the authority to proceed afresh in accordance with law.

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