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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.
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.
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