Reassessment Quashed: 148 Notice Issued Post 01.04.2021 Without Following New Law Held Invalid

Mahender Merugu Vs ITO (ITAT Hyderabad) In this case, the assessee challenged the validity of reassessment initiated under Section 148, arguing that the notice, though dated 31.03.2021, was actually issued on 01.04.2021 and therefore the amended provisions of Section 148A (introduced by Finance Act, 2021) should have been followed. The ITAT examined the dispatch records  and found that although the notice was dated 31.03.2021, it was handed over to the postal authorities only on 01.04.2021 at 14:48 hours, and even emailed later. Hence, the notice was effectively issued on or after 01.04.2021,...