On writ petitions challenging the notices for reassessment issued under section 148 of the Income-tax Act, 1961 after April 1, 2021 for periods prior to April 1, 2021 on the grounds that they were issued without following the procedure laid down under section 148A which was inserted with effect from April 1, 2021 Court held that all the notices for reassessment were to be quashed. The Department did not dispute the factual contentions of the assessee. Court also held that notification dated March 31, 2021 issued by the CBDT substitution of reassessment provisions framed under the Finance Act, 2021 was not deferred nor could they have been deferred. The date of such amendments coming into effect remained April 1, 2021.