Assessee challenged reopening notice under section 148 issued against it dated 30-6-2021 on grounds that same was issued without following procedure under section 148A which came into force on 1-4-2021 by Finance Act, 2021 and without giving assessee an opportunity of being heard and hence was illegal. Court held that individual identity of section 148, which was prevailing prior to amendment and insertion of section 148A was insulated and saved uptill 30-6-2021 therefore notice dated 30-6-2021 did not require any interference and same was held to be valid (AY. 2013-14, 2014-15, 2015-16)
Labtund Infrastructure (P.) Ltd. v. P CIT (2022) 284 Taxman 399 (Chhattisharh)(HC) Ashok Kumar Agrawal v. UOI (2022) 284 Taxman 342 (Chhattisgarh)(HC)/Sanjay Agrawal v.PCIT( 2022) 285 Taxman 576 (Chhattisgargarh)(HC)
S. 148 : Reassessment-Notice-Constitutional validity-Without following the procedure-Issue of notice is held to be valid. [S. 147, 148A, 149, 151, 151A, 153, 292 Relaxation of Certain Provisions) Act, 2020 (TOLA), S. 3(1) of the Act 38 of 2020, Art. 226]