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    <title>2021 (12) TMI 664 - DELHI HIGH COURT</title>
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    <description>Reopening of income-tax assessments: HC held that substituted procedural regime for Sections 147151, introduced by the Finance Act, 2021, took effect from 1 April 2021 and governs notices issued on or after that date. Executive notifications under the Relaxation Act, 2020 could only extend timelines and could not revive or prolong the erstwhile reassessment procedure; Explanations purporting to do so were ultra vires and inconsistent with the parent statutes. As a result, reassessment notices issued under Section 148 after 31 March 2021 that did not comply with the substituted procedure were quashed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=415898</link>
      <description>Reopening of income-tax assessments: HC held that substituted procedural regime for Sections 147151, introduced by the Finance Act, 2021, took effect from 1 April 2021 and governs notices issued on or after that date. Executive notifications under the Relaxation Act, 2020 could only extend timelines and could not revive or prolong the erstwhile reassessment procedure; Explanations purporting to do so were ultra vires and inconsistent with the parent statutes. As a result, reassessment notices issued under Section 148 after 31 March 2021 that did not comply with the substituted procedure were quashed.</description>
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