Court Rules Misinterpretation of Directive Invalidates Tax Notices; Upholds Assessee Rights u/s 148A.

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....Validity of reassessment proceedings - scope of new regime u/s 148A - The High Court found that the respondents misinterpreted the Supreme Court's directive in Union of India & Ors. vs. Ashish Agarwal. The directive was not to reopen completed assessments but to treat notices issued post-April 1, 2021, under the unamended provisions as if they were issued under the new provisions of Section 148A. - The Court underscored that the procedural safeguards introduced by the Finance Act, 2021, through Section 148A were aimed at protecting the assessee's rights. - Consequently, the Court quashed the impugned SCN issued u/s 148A(b), the order u/s 148A(d), and the notice u/s 148.....