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    <title>2022 (3) TMI 1435 - DELHI HIGH COURT</title>
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    <description>Reassessment notices issued after 1 April 2021 had to comply with the substituted Sections 147 to 151 of the Income-tax Act, 1961, because the amended regime had already come into force. Executive notifications under the relaxation statute could extend time limits, but could not defer or override the operation of the substituted reassessment provisions. The impugned explanations were therefore contrary to the parent statute and the later parliamentary enactment. The notices under Section 148 were invalid, the explanations were ultra vires and void, and the writ petitions were allowed with the notices quashed.</description>
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      <title>2022 (3) TMI 1435 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=304851</link>
      <description>Reassessment notices issued after 1 April 2021 had to comply with the substituted Sections 147 to 151 of the Income-tax Act, 1961, because the amended regime had already come into force. Executive notifications under the relaxation statute could extend time limits, but could not defer or override the operation of the substituted reassessment provisions. The impugned explanations were therefore contrary to the parent statute and the later parliamentary enactment. The notices under Section 148 were invalid, the explanations were ultra vires and void, and the writ petitions were allowed with the notices quashed.</description>
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