Section 147 Notices for 2013-14 and 2014-15 Assessments Are Time-Barred, Cannot Be Issued Under Amended Provisions.

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....Reopening of assessment u/s 147 - Validity of order u/s 148A - all such notices when they would relate to Assessment Year 2013-14 or Assessment Year 2014-15 would be time barred as per the provisions of the Act as applicable in the old regime prior to 01.04.2021. Furthermore, these notices cannot be issued as per the amended provision of the Act. - HC....