Assessee challenged constitutional validity of Explanation contained in Notification No. 20 of 2021, dated 31-3-2021 as well as Notification No. 38 of 2021, dated 27-4-2021 issued by CBDT by exercising powers conferred by section 3 of TLA Act, 2020 contending that even though section 148 was substituted by Finance Act, 2021 w.e.f. 1-4-2021, said notifications allowed revenue to issue reassessment notice under old provisions of section 148, notice. Notice is issued. Ad-interim order in terms of paragraph 7 (d) till returnable date.
Bharti Hiren Uttamchandani v. UOI [2022] 285 Taxman 385 (Guj.)(HC)/Shilp Associates. v. UOI(2022) 286 Taxman 242 (Guj)(HC)
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Writ petition filed by assessee challenging consequential notice issued under section 148 on 30-6-2021-Notice issued [S. 148, Taxation and Other laws. (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3(1), Art. 226]