In Brief
The Supreme Court addressed whether reassessment notices issued under the unamended Income Tax Act after 1st April 2021 (when the Finance Act 2021 amendments came into force) were valid. Multiple High Courts had quashed approximately 90,000 such notices, leading to 9,000+ writ petitions. Rather than sustain the quashing, the Supreme Court recharacterized the notices as show-cause notices under the new Section 148A regime. The Revenue must now provide information to assessees within 30 days; assessees may respond within two weeks. The assessing officer must then pass a decision under Section 148A(d) with all procedural safeguards and assessee defenses remaining available. This order applies pan-India to resolve the uniform issue across all High Courts."
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