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TMI Blog2024 (12) TMI 1269X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessment/reassessment is pending u/s 147 of the Act - scope of notices issued under Section 148 of the new regime between July and September 2022 - Application of TOLA to the Income Tax Act after 1 April 2021 -HELD THAT:- As decided in RAJEEV BANSAL [ 2024 (10) TMI 264 - SUPREME COURT (LB)] a notice could be issued under Section 148 of the new regime for assessment year 2021-2022 and before only ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dani, Mr. Salil Kapoor, Mr. Tarun Chanana, Ms. Ananya Kapoor, Mr. Utkarsa Gupta, Mr. Shivam Yadav, Advs. For the Respondents Through: Mr. Sanjay Kumar, Sr. SC with Ms. Monica Benjamin, Jr. SC and Ms. Easha Kadian, Jr. SC ORDER 1. The instant writ petition assails the reassessment action initiated under Section 148 of the Income Tax Act, 1961 [ Act ] for Assessment Year [ AY ] 2015-2016. The petiti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ons) Act, 2020 applies to the entire Income-tax Act, including sections 149 and 151 of the new regime. Once the first proviso to section 149 (1) (b) is read with Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, then all the notices issued between April 1, 2021 and June 30, 2021 pertaining to the assessment years 2013-2014, 2014-2015, 2015-2016, 2016-2017, and 201 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on and Amendment of Certain Provisions) Act, 2020. 3. In view of the aforesaid, it is evident that the impugned reassessment action for AY 2015-16 would not sustain. 4. The writ petition is accordingly allowed. The impugned order under Section 148A (d) of the Act dated 23 July 2022 and consequential notice referable to Section 148 of even date are hereby quashed and set aside. - - TaxTMI - TMI ..... X X X X Extracts X X X X X X X X Extracts X X X X
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