Old provisions of section 148 including TOLA cannot be applied to new regime: Calcutta HC

Arati Marketing Pvt. Ltd. Vs Union of India & Ors. (Calcutta High Court) Calcutta High Court held that the provisions of old regime of Section 148 of the Income Tax Act (including TOLA) cannot be applied to new regime applicable from 01.04.2021. Accordingly, impugned notices quashed being barred by limitation. Facts- Vide the present writ petitions, the petitioners are impugning notices issued on or after 1st April, 2021, u/s. 148 (old) of the Income Tax Act, 1961, by converting or treating the same u/s. 148A(b) of the Income Tax Act, 1961 inserted by the Finance Act, 2021 which came into ...