Allowing the petition the Court held that the newly inserted section 148A of the Income-tax Act, 1961 now specifically provides for issuance of a notice if the Assessing Officer takes a decision to initiate reassessment and therefore, a procedure has been laid down under section 148A which is required to be adhered to by the Assessing Officer after April 1, 2021, i. e., the date on which the Finance Act, 2021 ([2021] 432 ITR (St.) 52) came into force. After April 1, 2021, it is a mandatory requirement that prior to reassessment proceedings notice under section 148A of the Act should be issued to the assessee. On the facts  it was not disputed that the notice was in fact issued under section 148 on April 16, 2021 though the date thereon was mentioned as March 31, 2021. The notice was not valid.