On writ challenging the issue of notice u/s 148 allowing the revenue to issue reassessment notice under old provisions of section 148 read with section 149 of the Act as per section 3 of the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. . Notice was to be issued to revenue and Attorney General of India . Order was passed staying the proceedings till next date of hearing .
Tata Communications Transformation Services Ltd v. UOI (2021) 281 taxman 222 (Bom.) (HC) Sahil International v. ACIT (2021) 281 Taxman 221 (Bom.) ( HC)
S. 148 : Reassessment – Notice – Constitutional validity – Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 – CBDT’s notification No. 20/2021, dated 31-03-2021 – Notice issued under old provisions of section 148 on or after 1-4-2021- , Notice was issued to revenue and Attorney General of India- Order passed staying the proceedings till next date of hearing . [ S. 147, 148A, 149, TLA Act, 2020 , S. 3 , Art , 226 ]