Validity of reopening of assessment - scope of old unamended law...

Validity of reopening of assessment - scope of old unamended law and new inserted section 148A - The High court held that notices issued under the newly inserted Section 148A(b), treating them as if issued under the old Section 148 post-April 1, 2021, for assessment years 2013-14 and 2014-15 were invalid. The court found that the extension of time for issuing notices under the old Section 148, based on TOLA and subsequent CBDT notifications, was unauthorized after the old provisions were superseded by the Finance Act, 2021, without any saving clause for the old reassessment provisions.