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X X X X Extracts X X X X X X X X Extracts X X X X ..... o. 1747 of 2021, W.P.O. No. 1749 of 2021, W.P.O. No. 1751 of 2021, W.P.O. No. 1752 of 2021, W.P.O. No. 1754 of 2021, W.P.O. No. 1757 of 2021, W.P.O. No. 1760 of 2021, W.P.O. No. 1761 of 2021, W.P.O. No. 1762 of 2021, W.P.O. No. 1763 of 2021, W.P.O. No. 1764 of 2021, W.P.O. No. 1766 of 2021, W.P.O. No. 1785 of 2021, W.P.O. No. 1788 of 2021, W.P.O. No. 1789 of 2021, W.P.O. No. 1790 of 2021, W.P.O. No. 1792 of 2021, For the Petitioners :- Mr. Pranit Bag, Mr. Anuj Kr. Mishra, Mr. Balaram Patra, Mr. Sumit Mishra, Mr. Anurag Bagaria, Mr. V. N. Dwivedi, Ms. Jayanti Char, Mr. Saumya Kejriwal, Mr. Somnath Saha, Mr. Bhaskar Sengupta, Mr. S. K. Mukhi, Ms. Aishwarya Rajyashree, Mr. Arun Kumar Upadhyay, Ms. Shobha Upadhyay, Ms. Anupa Banerjee, Mr. Aasish Choudhury, Mrs. Aindrila Basu, Mr. Deepak Chopra, Mr. Rohan Khare, Mr. Indranil Banerjee, Mr. Subrata Mukherjee, Mr. D. B. Thakur, Mr. Himangshu Kr. Ray, Mr. A. Sengupta, Ms. Amani Kayan, Mr. Zubeen Pandey, Mr. Ankit Agarwal, Mr. Sumit Biswas, Mr. Rajashree Bhowmick, Mr. Sarangam Chakraborty, Ms. Swapna Das, Adv. Mr. Siddharth Das, Mr. J. P. Khaitan, Mr. Sanjay Bhowmik, Adv. Mr. A. K. Dey, Mr. P. Jhunjhunwala, Mr. Abhratosh Majumdar, Mr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the present common judgment and order. Common facts and issues involved in all these Writ Petitions as appear on perusal of relevant record and upon considering the submissions of the parties are that the petitioners are aggrieved by the issuance of impugned notices under Section 148 of the Income Tax Act, 1961 on the ground that the same are barred by limitation and the respondent Income Tax Authority concerned, before issuing the impugned notices under Section 148 of the Income Tax Act, have not observed the statutory formalities under Section 148 A of the Income Tax Act as prescribed by the Finance Act, 2021 which are applicable with effect from 1st April, 2021 before issuance of notices under Section 148 of the Act on or after 1st April, 2021. Issues arising in all the present Writ Petitions are purely legal and in all these Writ Petitions the assessees/petitioners have sought relief of quashing of the impugned re-assessment notices issued post 31st March, 2021 by the respondent Income Tax Authority concerned under Section 148 of the Income Tax Act, assessees/petitioners have also sought relief by way of a declaration declaring Explanations A(a)(ii)/A(b) to the Notificati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 'reassessment' appearing in the Notifications issued under the Enabling Act may be read to be indicating only at proceedings already commenced prior to 01.04.2021, under the Act (before amendment by the Finance Act, 2021). The delegated action performed under the Enabling Act cannot, itself create an overriding effect in favour of the Enabling Act. iii) The Enabling Act read with its Notifications does not validate the initiation of any proceeding that may otherwise be incompetent under the law. That law only affects the time limitation to conduct or conclude any proceeding that may have been or may be validly instituted under the Act, whether prior to or after its amendment by Finance Act, 2021. Insofar as, Section 1(2)(a) unequivocally enforced Sections 2 to 88 of the Finance Act, 2021, w.e.f. 01.04.2021, there can be no dispute if any valid proceeding could be initiated under the pre-existing Section 148 read with Section 147, after 01.04.2021. In support thereof other submission also appear to exist - based upon the enactment of Section 148A (w.e.f. 01.04.2021). (iv) The delegation made could be exercised within the four corners of the principal legislation and not to overr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ter does not require any further examination. 65. Therefore, other things apart, undeniably, on 01.04.2021, by virtue of plain/unexpected effect of Section 1(2)(a) of the Finance Act, 2021, the provisions of Sections 147, 148, 149, 151 (as those provisions existed up to 31.03.2021), stood substituted, along with a new provision enacted by way of Section 148A of that Act. In absence of any saving clause, to save the pre-existing (and now substituted) provisions, the revenue authorities could only initiate reassessment proceeding on or after 01.04.2021, in accordance with the substituted law and not the pre-existing laws. 66. It is equally true that the Enabling Act that was preexisting, had been enforced prior to enforcement of the Finance Act, 2021. It confronted the Act as amended by Finance Act, 2021, as it came into existence on 01.04.2021. In the Enabling Act and the Finance Act, 2021, there is absence, both of any express provision in itself or to delegate the function - to save applicability of the provisions of sections 147, 148, 149 or 151 of the Act, as they existed up to 31.03.2021. Plainly, the Enabling Act is an enactment to extend timelines only. Consequently, it f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ings already under way. There is nothing in the language of that provision to admit a wider or sweeping application to be given to that clause - to serve a purpose not contemplated under that provision and the enactment, wherein it appears. 70. The upshot of the above reasoning is, the Enabling Act only protected certain proceedings that may have become time barred on 20.03.2020, up to the date 30.06.2021. Correspondingly, by delegated legislation incorporated by the Central Government, it may extend that time limit. That time limit alone stood extended up to 30 June, 2021. We also note, the learned Additional Solicitor General of India may not be entirely correct in stating that no extension of time was granted beyond 30.06.2021. Vide Notification No. 3814 dated 17.09.2021, issued under section 3(1) of the Enabling Act, further extension of time has been granted till 31.03.2022. In absence of any specific delegation made, to allow the delegate of the Parliament, to indefinitely extend such limitation, would be to allow the validity of an enacted law i.e. the Finance Act, 2021 to be defeated by a purely colourable exercise of power, by the delegate of the Parliament. 71. Here, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ovisions regarding reassessment with new provisions w.e.f. 01.04.2021), the mischief rule has no application. 75. As we see there is no conflict in the application and enforcement of the Enabling Act and the Finance Act, 2021. Juxtaposed, if the Finance Act, 2021 had not made the substitution to the reassessment procedure, the revenue authorities would have been within their rights to claim extension of time, under the Enabling Act. However, upon that sweeping amendment made the Parliament, by necessary implication or implied force, it limited the applicability of the Enabling Act and the power to grant time extensions thereunder, to only such reassessment proceedings as had been initiated till 31.03.2021. Consequently, the impugned Notifications have no applicability to the reassessment proceedings initiated from 01.04.2021 onwards. 76. Upon the Finance Act 2021 enforced w.e.f. 1.4.2021 without any saving of the provisions substituted, there is no room to reach a conclusion as to conflict of laws. It was for the assessing authority to act according to the law as existed on and after 1.4.2021. If the rule of limitation permitted, it could initiate, reassessment proceedings in a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ture. Second, it would be over simplistic to ignore the provisions of, either the Enabling Act or the Finance Act, 2021 and to read and interpret the provisions of Finance Act, 2021 as inoperative in view of the fact circumstances arising from the spread of the pandemic COVID19. Practicality of life de hors statutory provisions, may never be a good guiding principle to interpret any taxation law. In absence of any specific clause in Finance Act, 2021, either to save the provisions of the Enabling Act or the Notifications issued thereunder, by no interpretative process can those Notifications be given an extended run of life, beyond 31 March 2020. They may also not infuse any life into a provision that stood obliterated from the statute with effect from 31.03.2021. Inasmuch as the Finance Act, 2021 does not enable the Central Government to issue any notification to reactivate the pre-existing law (which that principal legislature had substituted), the exercise made by the delegate/Central Government would be de hors any statutory basis. In absence of any express saving of the pre-existing laws, the presumption drawn in favour of that saving, is plainly impermissible. Also, no presum ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent notices relating to any Assessment Year issued under Section 148 after 31st March, 2021 had to comply with the substituted Sections. 98. It is clarified that the power of reassessment that existed prior to 31st March, 2021 continued to exist till the extended period i.e. till 30th June, 2021; however, the Finance Act, 2021 has merely changed the procedure to be followed prior to issuance of notice with effect from 1st April, 2021. 99. This Court is of the opinion that Section 3(1) of Relaxation Act empowers the Government/Executive to extend only the time limits and it does not delegate the power to legislate on provisions to be followed for initiation of reassessment proceedings. In fact, the Relaxation Act does not give power to Government to extend the erstwhile Sections 147 to 151 beyond 31st March, 2021 and/or defer the operation of substituted provisions enacted by the Finance Act, 2021. Consequently, the impugned Explanations in the Notifications dated 31st March, 2021 and 27th April, 2021 are not conditional legislation and are beyond the power delegated to the Government as well as ultra vires the parent statute i.e. the Relaxation Act. Accordingly, this Court is r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd void. 105. Consequently, the impugned reassessment notices issued under Section 148 of the Income Tax Act, 1961 are quashed and the present writ petitions are allowed. If the law permits the respondents/revenue to take further steps in the matter, they shall be at liberty to do so. Needless to state that if and when such steps are taken and if the petitioners have a grievance, they shall be at liberty to take their remedies in accordance with law." Respectfully agreeing with the reasonings and views taken by the Allahabad High Court, Rajasthan High Court and Delhi High Court in the cases referred hereinabove, all these Writ Petitions herein are disposed of by allowing the same. Explanations A(a)(ii)/A(b) to the Notifications dated 31st March, 2021 and 27th April, 2021 are declared to be ultra vires the Relaxation Act, 2020 and are therefore bad in law and null and void. All the impugned notices under Section 148 of the Income Tax Act are quashed with liberty to the Assessing Officers concerned to initiate fresh re-assessment proceedings in accordance with the relevant provisions of the Act as amended by Finance Act, 2021 and after making compliance of the formalities as requ ..... X X X X Extracts X X X X X X X X Extracts X X X X
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