Observation of the case could be summarised as under:
• Revenue could initiate reassessment proceeding on or after 1-4-2021, only in accordance with the mandatory procedure in section 148A and the substituted sections 147 to 149 &151.
• Section 148A and amended provisions are not applicable only in cases where reassessment notice has been issued under pre-amended provisions on or before 31-3-2021.
• Where reassessment notice is issued on or after 1-4-2021 without complying with the mandatory procedure of section 148A of the Act and the substituted sections 147 to 149 &151, the reassessment notice issued u/s 148 deserves to be quashed.
• However, it is left open to the assessing authority to initiate reassessment proceedings in accordance with the provisions of the Act, as amended by the Finance Act, 2021 after making due compliance as required under the law.
