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Ashish Agarwal - Reassessment scheme

Supreme Court of India·2022·ITR
Facts

Reassessment notices issued under old Section 148 between April-June 2021 challenged after enactment of new reassessment scheme.

Issue

Whether notices under old regime are valid post-amendment?

Held

Such notices to be treated as notices under Section 148A(b) of the new regime; AO must complete the inquiry under the new procedure.

Ratio

Transitional reading to avoid prejudice to revenue and uphold legislative intent.

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