Court Rules on Section 147: Time-Barred Tax Notices Can't Be Revived, Invalid Notices Issued Post-April 1, 2021, Struck Down.

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....Reopening of assessment u/s 147 - extension of period of limitation from 6 years to 10 years - In plain terms a notice which had become time barred prior to 01.04.2021 as per the then prevailing provisions, would not be revived by virtue of the application of Section 149(1)(b) effective from 01.04.2021. All the notices issued in the present cases are after 01.04.2021 and have been issued without following the procedure contained in Section 148A of the Act and are therefore invalid. - HC....