Reassessment notices under the new tax procedure were quashed for non-compliance with the Finance Act, 2021 regime.

Reassessment notices issued under Section 148 and the consequential orders were held unsustainable where they did not conform to the substituted procedure introduced by the Finance Act, 2021. The Court applied its earlier settled view that, once reassessment is governed by the new statutory regime, notices and further proceedings must strictly comply with that substituted framework; proceedings taken outside it are contrary to law. On that basis, the impugned notices and consequential orders were set aside and quashed, and the writ petitions were allowed.

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Issues: Whether the show-cause notices issued for reassessment under Section 148 of the Income-tax Act, 1961 and the consequential orders could be sustained after the change brought about by the Finance Act, 2021.

Analysis: The parties agreed that the controversy stood covered by an earlier common order of the Court holding that, once reassessment proceedings were to be dealt with under the substituted procedure introduced by the Finance Act, 2021, notices and further proceedings not taken in conformity with that substituted regime were contrary to law. The Court therefore applied the same settled position to the present batch of writ petitions.

Conclusion: The impugned notices and consequential orders were set aside and quashed, and the writ petitions were allowed.

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