No reassessment for Assessment years 2013-14 & 2014-15 if notices issued under old provision between 01.04.2021 to 30.06.2021

Sumit Jagdishchandra Agrawal Vs DCIT (Gujarat high court) All original notices under section 148 referable to old regime and issued between 01.04.2021 to 30.06.2021 would stand beyond prescribed permissible timeline of six years from end of assessment year 2013-14 and assessment year 2014-15. Therefore, all such notices when they would relate to assessment year 2013-14 or assessment year 2014-15 would be time barred as per provisions of Act as applicable in old regime prior to 01.04.2021. Further, these notices could not be issued as per amended provision of Act. In view of above, impugned not...