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Determination of Date of Issue vis-a-vis Various modes of Issue of Notice – Delhi HC in Suman Jeet & Ors
Introduction:
Issue of Notice under section 148 of ITA[1] after 31.03.2021 under old provisions has created a buzz in the reassessment matter in recent times. Finally, the matter reached the Supreme Court in the case of Ashish Agarwal[2] and CBDT[3] has issued an instruction[4] to implement the decision of Supreme Court. For detailed analysis of the above issue, read our article here[5].
When the above issue is taking the discussion at various judicial fora, parallelly, one more issue has stood up and raised its voice to make a big impact in the reassessment controversy.
Section 149 (old provisions as well as amended provisions) states that the Notice under section 148 shall not be ‘issued’ after the expiry of time limit specified in section 149 for making the reassessment under section 147.