https://www.taxtmi.com/caselaws?id=782644 The ITAT Delhi set aside the reassessment framed u/s 147 on the ground of invalid initiation under the amended reassessment regime. The notice u/s 148, though digitally signed on 31.03.2021, was issued/uploaded on the ITBA portal on 01.04.2021, making it a notice governed by the Finance Act, 2021 amendments as clarified by the SC in Ashish Agarwal. Consequently, the AO was required to comply with the mandatory procedure u/ss 148 and 148A, including enquiry u/s 148A(a), opportunity of hearing u/s 148A(b), and order u/s 148A(d) with prior approval. As these requirements were not followed, the reassessment was held void and the assessee's appeal was allowed. en-us Fri, 21 Nov 2025 00:00:00 +0530 Tue, 02 Dec 2025 08:35:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782644 The ITAT Delhi set aside the reassessment framed u/s 147 on the ground of invalid initiation under the amended reassessment regime. The notice u/s 148, though digitally signed on 31.03.2021, was issued/uploaded on the ITBA portal on 01.04.2021, making it a notice governed by the Finance Act, 2021 amendments as clarified by the SC in Ashish Agarwal. Consequently, the AO was required to comply with the mandatory procedure u/ss 148 and 148A, including enquiry u/s 148A(a), opportunity of hearing u/s 148A(b), and order u/s 148A(d) with prior approval. As these requirements were not followed, the reassessment was held void and the assessee's appeal was allowed. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782644