TMI Blog2022 (2) TMI 1258X X X X Extracts X X X X X X X X Extracts X X X X ..... es treating the time line for issuance of notice under Section 148 (unamended) extended upto 30th June, 2021 - HELD THAT:- Referring to the amendment made in Sections 147 to 151 of the Act of 1961 with effect from 1st April, 2021 by the Finance Act, 2021, it is submitted that Madras High Court has taken note of the decisions of the Delhi High Court, Calcutta High Court, Allahabad High Court and other High Courts and quashed the impugned reassessment notices issued under Section 148 of the Act, 1961. However, liberty has been granted to the Revenue to initiate reassessment proceedings in accordance with the provisions of the Act of 1961, as amended by the Finance Act, 2021, after making all the compliances as required by law, if limitation f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... notices issued under Section 148 (Unamended) of Income Tax Act, 1961 in these respective writ petitions. Petitioner in W.P (T) No. 5376 of 2021 has assailed the notices dated 01.04.2021 and 15.04.2021 (Annexue-1). Similarly in W.P.(T) No. 5412 of 2021 the impugned notice is dated 29.06.2021 (Annexure-1). In W.P.(T) No. 144 of 2022 impugned notice is dated 30.06.2021 (Annexure- 1). In W.P.(T) No. 145 of 2022 impugned notice is dated 24.05.2021 (Annexure-1). 2. It is the case of the petitioners that Section 148 has undergone an amendment and amended Sections 148 and 148A have come into force with effect from 1st April, 2021. The Revenue relying upon the Taxation and other Laws (Relaxation in Amendment of Certain Provisions) Act, 2020 has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ification no. 20, dated 31st March, 2021 and Notification no. 38, dated 27th April, 2021 inasmuch as they extend the applicability of the provisions of Sections 148, 149 and 151 of the Income Tax Act, 1961 as it stood as on 31st March, 2021, to the period beyond 31st March, 2021. Petitioners therein had also laid challenge to the reassessment notices issued under Section 148 of the Act of 1961. Referring to the amendment made in Sections 147 to 151 of the Act of 1961 with effect from 1st April, 2021 by the Finance Act, 2021, it is submitted that Madras High Court has taken note of the decisions of the Delhi High Court, Calcutta High Court, Allahabad High Court and other High Courts and quashed the impugned reassessment notices issued under ..... X X X X Extracts X X X X X X X X Extracts X X X X
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