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    <description>Reassessment notices issued after 31 March 2021 had to comply with the substituted Sections 147 to 151 of the Income-tax Act introduced by the Finance Act, 2021 from 1 April 2021. The extended time allowed by relaxation legislation could not revive or continue the earlier reassessment procedure beyond that date, because notifications may extend limitation periods but cannot override the statutory replacement enacted by Parliament. The saving provision under the General Clauses Act was held inapplicable where a fresh legislative framework had superseded the old one on the same subject. Explanations in the notifications that attempted to sustain notices under the earlier regime were therefore beyond delegated power and void.</description>
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