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2022 (6) TMI 1431 - HC - Income TaxReopening of assessment u/s 147 - procedure laid down u/s 148A - scope of new provisions substituted by the Finance Act, 2021 - section 148 notice issued on or after 1st April, 2021 - eligibility of reasons to believe that income chargeable to tax had escaped assessment - HELD THAT:- As decided by Ashish Agarwal [2022 (5) TMI 240 - SUPREME COURT] case the new provisions substituted by the Finance Act, 2021 being remedial and benevolent in nature and substituted with a specific aim and object to protect the rights and interest of the assessee as well as and the same being in public interest, the respective High Courts have rightly held that the benefit of new provisions shall be made available even in respect of the proceedings relating to past assessment years, provided section 148 notice has been issued on or after 1st April, 2021. We are in complete agreement with the view taken by the various High Courts in holding so. The present batch of writ petitions would stand disposed of in terms of the judgment of the Supreme Court in Ashish Agarwal (supra). However, there shall be no order as to costs.
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