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HC justified action of AO in issuing reassessment notice under old provisions after 31-03-2021

September 8, 2021[2021] 130 132 (Chhattisgarh)

INCOME TAX : Where assessee-firm challenged notice issued under section 148 on 30-6-2021 on grounds that same was issued without following procedure under section 148A which came into force on 1-4-2021 by Finance Act, 2021 and without giving assessee an opportunity to be heard, in view of fact that pandemic and lockdown prevailed all over India and people were unable to file their returns and considering said situation Ministry of Finance had issued Notification No. 20/2021, dated 31-3-2021 and Notification No. 38/2021, dated 27-4-2021 in exercise of power conferred under Taxation and other laws (Relaxation and Amendment of certain provisions) Act, 2020, extending time-limit for issuance of notice under provisions of section 148 which was prevailing prior to amendment of Finance Act, 2021 till 30-6-2021, in view of same impugned notice issued on 30-6-2021 does not require any interference

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