Reassessment notices issued 1 Apr-30 Jun 2021 treated as deemed show-cause; s.148 requires s.149(1) period and prior s.151 approval

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....The HC holds that reassessment notices issued between 1 Apr 2021 and 30 Jun 2021 under the pre-existing regime are to be treated as deemed show-cause notices under the new reassessment law, with the residual limitation computed up to 30 Jun 2021 under TOLA. For valid exercise of jurisdiction under s.148 of the new regime, the AO must issue notices within the surviving period read with s.149(1) and obtain prior approval under s.151; non-compliance renders the notice and consequential assessment void. Consequently, the s.148A(d) order dated 25.07.2022, the s.148 notice dated 25.07.2022 and the assessment order purportedly passed on 22.05.2023 are set aside.....