https://www.taxtmi.com/caselaws?id=421980 The SC held that reassessment notices issued under the unamended section 148 after 01.04.2021 should be deemed issued under the new section 148A introduced by the Finance Act, 2021. High Courts erred in quashing such notices outright, as this would frustrate the purpose of reassessment proceedings and leave Revenue remediless. The Court exercised its Article 142 powers to direct that all similar High Court judgments setting aside reassessment notices issued post-amendment be modified accordingly, permitting reassessment to proceed under the substituted sections 147 to 151, subject to procedural compliance and available defenses. This order applies PAN INDIA, governs pending writs, and aims to avoid thousands of appeals, balancing Revenue's interests and taxpayers' rights in light of bona fide mistakes by Revenue officers regarding the amendment's enforcement. en-us Wed, 04 May 2022 00:00:00 +0530 Mon, 11 Aug 2025 17:30:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=421980 The SC held that reassessment notices issued under the unamended section 148 after 01.04.2021 should be deemed issued under the new section 148A introduced by the Finance Act, 2021. High Courts erred in quashing such notices outright, as this would frustrate the purpose of reassessment proceedings and leave Revenue remediless. The Court exercised its Article 142 powers to direct that all similar High Court judgments setting aside reassessment notices issued post-amendment be modified accordingly, permitting reassessment to proceed under the substituted sections 147 to 151, subject to procedural compliance and available defenses. This order applies PAN INDIA, governs pending writs, and aims to avoid thousands of appeals, balancing Revenue's interests and taxpayers' rights in light of bona fide mistakes by Revenue officers regarding the amendment's enforcement. Case-Laws Income Tax Wed, 04 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=421980