Allowing the petition the Court held that in view of the concession made by the Department in Union of India v. Rajeev Bansal, (2024) 469 ITR 46 (SC) that for the assessment year 2015-2016, all notices issued on or after April 1, 2021 would have to be dropped as they would not fall for completion during the period prescribed under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, the notices dated June 25, 2021 were liable to be quashed.
Deepak Steel and Power Ltd. v. CBDT (2025) 476 ITR 369 /305 Taxman 169 (SC) Editorial : Decision of Orissa High Court reversed, Deepak Steel and Power Ltd. v. CBDT (WP Nos. 2446 of 2023, 2543 of 2023 dt 1-2-2023
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-High Court holding writ will not lie and grievances on merits to be agitated by assessees in reassessment proceedings before Assessing Officer-Supreme Court Concession of Department before Supreme Court in UOI v. Rajeev Bansal (2024) 469 ITR 46(SC) that all notices issued on or after 1-4-2021 would have to be dropped as they would not fall for completion during period prescribed under Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020-Notices dated 25-6-2021 quashed.[S. 147, 148, 148A(b), (d) Art, 226.]