https://www.taxtmi.com/caselaws?id=304688 After 1 April 2021, reassessment notices had to comply with the substituted reassessment procedure, and notices issued later could not rely on the superseded pre-existing regime. The court further treated the explanations inserted in the time-extension notifications as ultra vires to the extent they attempted to preserve the earlier procedure, because delegated power could extend time limits but could not override the new statutory scheme. On that basis, the notices under section 148 issued on the old footing were quashed and the reassessment proceedings were held unsustainable. en-us Tue, 11 Jan 2022 00:00:00 +0530 Fri, 14 Oct 2022 20:57:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304688 After 1 April 2021, reassessment notices had to comply with the substituted reassessment procedure, and notices issued later could not rely on the superseded pre-existing regime. The court further treated the explanations inserted in the time-extension notifications as ultra vires to the extent they attempted to preserve the earlier procedure, because delegated power could extend time limits but could not override the new statutory scheme. On that basis, the notices under section 148 issued on the old footing were quashed and the reassessment proceedings were held unsustainable. Case-Laws Income Tax Tue, 11 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304688