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    <title>Notices digitally signed on 01.04.2021 treated as issued under substituted s.148A; AO must furnish material and follow s.148A procedure.</title>
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    <description>The HC held that reassessment proceedings cannot proceed under the unamended s.148 of the I.T. Act when a notice was digitally signed on 1.4.2021; such notice must be treated as issued under substituted s.148A and as a show-cause notice under s.148A(b). The AO is directed to furnish within 30 days the information/material relied upon; the petitioner may reply within two weeks. The requirement of prior approval under s.148A(a) is dispensed with as a one-time measure for notices issued from 01.04.2021. The AO shall pass an order under s.148A(d) and may thereafter follow s.148A procedure before issuing a substituted s.148 notice. All statutory and other defences, including under s.149, are preserved. The impugned assessment order is quashed and set aside.</description>
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    <pubDate>Fri, 14 Nov 2025 09:42:55 +0530</pubDate>
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      <title>Notices digitally signed on 01.04.2021 treated as issued under substituted s.148A; AO must furnish material and follow s.148A procedure.</title>
      <link>https://www.taxtmi.com/highlights?id=94163</link>
      <description>The HC held that reassessment proceedings cannot proceed under the unamended s.148 of the I.T. Act when a notice was digitally signed on 1.4.2021; such notice must be treated as issued under substituted s.148A and as a show-cause notice under s.148A(b). The AO is directed to furnish within 30 days the information/material relied upon; the petitioner may reply within two weeks. The requirement of prior approval under s.148A(a) is dispensed with as a one-time measure for notices issued from 01.04.2021. The AO shall pass an order under s.148A(d) and may thereafter follow s.148A procedure before issuing a substituted s.148 notice. All statutory and other defences, including under s.149, are preserved. The impugned assessment order is quashed and set aside.</description>
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      <pubDate>Fri, 14 Nov 2025 09:42:55 +0530</pubDate>
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