S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice-Limitation-Finance Act, 2021-Notice Issued on 30-7-2022-Reopen assessments for 2013-14 and 2014-15-Barred by limitation-The 2020 Act is a secondary legislation-Secondary legislation would not override the principal legislation, the Finance Act, 2021.. [S. 147, 148, 148A(b), 148A(d), 149, 151, Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3, Art. 226]
Sumit Jagdishchandra Agrawal v.Dy. CIT (2023)455 ITR 216 /148 taxmann.com 437 (Guj) (HC)