Reassessment Notice Served After 31 March 2021

The Mumbai Bench of the Income Tax Appellate Tribunal quashed reassessment proceedings initiated under Section 148 of the Income-tax Act on the ground that although the notice bore the date 31 March 2021, it was admittedly signed and served only on 7 April 2021. 

The Tribunal held that once the reassessment regime stood substituted with effect from 1 April 2021 by the Finance Act, 2021, any notice issued after that date necessarily had to comply with the amended framework, including Section 148A. Since the Department proceeded under the erstwhile regime, the reassessment was held to be barred by limitation and void ab initio.