Facts of the Case
- The petitioners filed multiple writ petitions challenging
reassessment notices issued after 01 April 2021.
- These notices were issued under the old provisions of Section
148, without following the newly introduced procedure under Section
148A.
- Petitioners contended that the Finance Act, 2021 had overhauled the
reassessment mechanism, making compliance with new provisions mandatory.
- The Revenue relied on TOLA to justify extension of timelines and
continuation of old provisions.
Issues Involved
- Whether reassessment notices issued after 01.04.2021 under old
Section 148 are valid.
- Whether TOLA permits extension of old reassessment provisions
beyond 31.03.2021.
- Whether the new procedure under Section 148A is mandatory for all
reassessment proceedings post amendment.
Petitioner’s Arguments
- The Finance Act, 2021 substituted Sections 147–151 entirely, making
the new regime mandatory from 01.04.2021.
- Notices issued under old provisions are ultra vires and void ab
initio.
- TOLA only extends timelines, not the applicability of repealed
provisions.
- Failure to follow Section 148A violates principles of natural
justice.
Respondent’s Arguments
- The Revenue argued that due to COVID-19 disruptions, TOLA extended
the time limits for issuing notices.
- It was contended that the old provisions continued to apply during
the extended period.
- Notifications issued under TOLA permitted continuation of
reassessment under the old regime.
Court Findings / Order
- The Court held that Finance Act, 2021 brought a substantive
change in law, not merely procedural.
- Once the new law came into force on 01.04.2021, old provisions
ceased to exist.
- TOLA cannot override or defer the applicability of substituted
statutory provisions.
- Reassessment notices issued under old Section 148 after 01.04.2021
were invalid.
- The Court granted interim protection and restrained reassessment proceedings pursuant to such notices.
Important Clarifications by Court
- Delegated legislation (notifications under TOLA) cannot override
parent statute amendments.
- Any reassessment initiated post 01.04.2021 must strictly comply
with Section 148A.
- Extension of limitation does not mean extension of repealed law.
- The new reassessment framework is mandatory and not optional.
Link to download the order -https://delhihighcourt.nic.in/app/case_number_pdf/2021:DHC:4492-DB/MMH06082021CW75092021_155145.pdf
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