Section 148 Notices Held Defective for Post-April Issuance Despite March Dating

Suman Jeet Agarwal Vs ITO (Delhi High Court) In this batch of petitions, the Delhi High Court examined the validity of reassessment notices issued under Section 148 of the Income Tax Act, 1961, as it existed before its amendment by the Finance Act, 2021, which came into effect on 1 April 2021. The dispute arose from a series of reassessment notices generated for Assessment Years (AYs) 2013-14 to 2017-18, all dated 31 March 2021, but electronically issued, dispatched, or received on or after 1 April 2021. The central question was whether these notices could be considered validly “issued” be...