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TMI Blog2021 (8) TMI 1425X X X X Extracts X X X X X X X X Extracts X X X X ..... whether provisions of Section 144B of the Act would apply to even those proceedings, which were pending, on 1st April 2021? HELD THAT:- Circular dated 31st March, 2021 issued by CBDT, Section 144B of the Act would apply to even those assessment proceedings which related to assessment years prior to 2021 provided they were pending disposal on 1st April, 2021. This Court is also of the view that Se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... HAN, J: (Oral) 1. The petition has been heard by way of video conferencing. 2. Present writ petition has been filed challenging the impugned assessment order dated 21st April 2021 passed by Respondent No. 1 under Section 143(3) read with 144B of the Income-tax Act, 1961 (for short the Act ). 3. Mr. Manuj Sabharwal, learned counsel for the Petitioner states that the impugned assessment order dated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 31st March, 2021, which is appended at pages 103-107 of the paper book to establish that the provisions of Section 144B of the Act would apply to even those proceedings, which were pending, on 1st April 2021 and hence would be applicable to the Petitioner s assessment as well. 7. Having heard learned counsel for the parties, this Court is of the opinion that in view of the Circular dated 31st Marc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... decide to xxxx xxxx xxxx (b) provide an opportunity to the assessee, in case any variation prejudicial to the interest of assessee is proposed, by serving a notice calling upon him to show cause as to why the proposed variation should not be made; or xxx xxx xxx (9) Notwithstanding anything contained in any other provision of this Act, assessment made under sub-section (3) of section 143 or under ..... X X X X Extracts X X X X X X X X Extracts X X X X
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