https://www.taxtmi.com/caselaws?id=456181 The substituted reassessment procedure under Sections 147 to 151 of the Income-tax Act, 1961 operated from 1 April 2021, so notices issued after 31 March 2021 had to follow the new statutory mechanism; notices issued under the old regime were invalid. The relaxation statute empowered extension of time limits only, not continuation of the earlier reassessment procedure or alteration of the substantive initiation framework, so the notifications and their explanations were ultra vires and void. As the impugned notices were issued under an inapplicable and invalid regime, they could not be sustained and were quashed. en-us Wed, 05 Jan 2022 00:00:00 +0530 Thu, 04 Jul 2024 23:20:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456181 The substituted reassessment procedure under Sections 147 to 151 of the Income-tax Act, 1961 operated from 1 April 2021, so notices issued after 31 March 2021 had to follow the new statutory mechanism; notices issued under the old regime were invalid. The relaxation statute empowered extension of time limits only, not continuation of the earlier reassessment procedure or alteration of the substantive initiation framework, so the notifications and their explanations were ultra vires and void. As the impugned notices were issued under an inapplicable and invalid regime, they could not be sustained and were quashed. Case-Laws Income Tax Wed, 05 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456181