Court Rules Against Reopening Completed Tax Assessments; Invalidates New Show Cause Notice u/s 148-A(b.

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....Validity of reopening an assessment and the legality of issuing a new Show Cause Notice u/s 148-A(b) after the conclusion of initial reassessment proceedings. The key points are: The respondents issued a Show Cause Notice u/s 148-A(b) on the premise that the Supreme Court's judgment in Ashish Agarwal requires all notices issued u/s 148 between April 1, 2021, and June 30, 2021, to be treated as notices u/s 148-A(b). However, the assessment proceedings in this case were already concluded on March 30, 2022. Subsequently, reassessment action was re-initiated on the same set of reasons via a Show Cause Notice dated June 2, 2022, u/s 148-A(b), leading to an order u/s 148-A(d) and a notice u/s 148 dated July 19, 2022. The High Court held that ther.........