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    <title>2026 (5) TMI 540 - ITAT DELHI</title>
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    <description>A section 148 notice issued on 1 April 2021 for assessment year 2013-14 was governed by the amended reassessment regime in force from that date, even though it was digitally signed on 31 March 2021. Under the amended scheme, the Assessing Officer had to follow section 148A, including enquiry where necessary, opportunity of hearing, and a speaking order before issuing the notice. As those mandatory steps were not followed, the notice was invalid and bad in law, and the reassessment proceedings founded on it lacked jurisdiction. The Revenue&#039;s appeal on merits therefore became academic.</description>
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    <pubDate>Wed, 15 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 540 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=791338</link>
      <description>A section 148 notice issued on 1 April 2021 for assessment year 2013-14 was governed by the amended reassessment regime in force from that date, even though it was digitally signed on 31 March 2021. Under the amended scheme, the Assessing Officer had to follow section 148A, including enquiry where necessary, opportunity of hearing, and a speaking order before issuing the notice. As those mandatory steps were not followed, the notice was invalid and bad in law, and the reassessment proceedings founded on it lacked jurisdiction. The Revenue&#039;s appeal on merits therefore became academic.</description>
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      <pubDate>Wed, 15 Apr 2026 00:00:00 +0530</pubDate>
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