Court held that held that virtue of Finance Act, 2021 provisions of sections 147 and 148 as existed upto 31-3-2021, stood substituted along with new provisions enacted by way of section 148A and in absence of any saving clause to save pre-existing provisions, revenue could only initiate reassessment proceedings on or after 1-4-2021 in accordance with substituted law. Accordingly reassessment notice issued under section 148 on 30-6-2021 without complying with substituted provisions of section 148A was quashed. Followed Ashok Kumar Agarwal v. UOI (2021) 131 taxmann.com 22 (All)(HC). (AY 2014-15)
ACIT v. Kirti Singh (2022) 138 taxmann.com 216 (All.)(HC) Editorial : Notice issued in SLP filed the Revenue, ACIT v. Kirti Singh (2022) 287 Taxman 647 (SC), Refer, UOI v. Ashish Agarwal (2022) 286 Taxman 183 (SC)
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Reassessment notice issued under section 148 on 30-6-2021 without complying with substituted provisions of section 148A was quashed. [S. 148 Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 S. 3]