Reassessment notices issued after 01.04.2021 must follow the amended regime; pre-amendment reopening was quashed.

Reassessment notices issued on or after 01.04.2021 were held to fall under the amended reassessment regime, and action taken under the pre-amendment framework on that basis was legally unsustainable. Because the notices were issued and dispatched after that date, the reassessment proceedings founded on them could not be continued. The reopening notices were therefore invalid and were quashed, with the result that the reassessments could not survive.

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Issues: Whether the reassessment notices issued under section 148 on or after 01.04.2021 could be sustained under the pre-amendment regime, and whether the reassessments founded on such notices were valid.

Analysis: The notices were issued and dispatched after 01.04.2021. The governing legal position treats such issuance as attracting the amended regime, and reassessment action taken under the old regime on or after that date is legally unsustainable.

Conclusion: The reopening notices were invalid and were quashed, with the result that the reassessment proceedings could not survive.

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