The HC held that reassessment proceedings cannot proceed under...

The HC held that reassessment proceedings cannot proceed under the unamended s.148 of the I.T. Act when a notice was digitally signed on 1.4.2021; such notice must be treated as issued under substituted s.148A and as a show-cause notice under s.148A(b). The AO is directed to furnish within 30 days the information/material relied upon; the petitioner may reply within two weeks. The requirement of prior approval under s.148A(a) is dispensed with as a one-time measure for notices issued from 01.04.2021. The AO shall pass an order under s.148A(d) and may thereafter follow s.148A procedure before issuing a substituted s.148 notice. All statutory and other defences, including under s.149, are preserved. The impugned assessment order is quashed and set aside.

---