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GOOD INFORMATION TO UPDATE THE TAX LAW
This instruction is violative of the decisions of the Supreme Court. In the judgement of Supreme Court it is made categorical that Sec.149 as introduced frofm 1-4-2021 would apply. As per this notice u/s.148 cannot be issued if as per provisions of Sec.149(1)(b) as it stood prior to 1-4-2021 it cannot be issued. Thus for the A.Y.2013-2014 and 2014-2015 the notice u/s.148 cannot be issued being beyond six years. But the CBDT in its instructions directs the Assessing Officers to re issue notices for 2013-2014 and 2014-2015. Thus the CBDT has not only violated the decision but has created litigation by forcing assessees to approach High Courts.