https://www.taxtmi.com/caselaws?id=421980 Reassessment notices issued on or after 01.04.2021 under the unamended regime could not survive after substitution of sections 147 to 151 by the Finance Act, 2021, because the new scheme introduced mandatory pre-notice safeguards, inquiry where required, a hearing opportunity, reasoned decision-making, and revised time-limits and sanction requirements. The SC held that such old-form notices had to be dealt with under the substituted framework rather than sustained as issued. Exercising Article 142, it directed that the notices be treated as section 148A(b) show-cause notices, required supply of relied-upon material, and permitted the reassessment process to continue under the amended procedure with all statutory and legal defences kept open. 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 Reassessment notices issued on or after 01.04.2021 under the unamended regime could not survive after substitution of sections 147 to 151 by the Finance Act, 2021, because the new scheme introduced mandatory pre-notice safeguards, inquiry where required, a hearing opportunity, reasoned decision-making, and revised time-limits and sanction requirements. The SC held that such old-form notices had to be dealt with under the substituted framework rather than sustained as issued. Exercising Article 142, it directed that the notices be treated as section 148A(b) show-cause notices, required supply of relied-upon material, and permitted the reassessment process to continue under the amended procedure with all statutory and legal defences kept open. Case-Laws Income Tax Wed, 04 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=421980