Key Points: - The Court holds that reassessment notices issued under unamended Section 148 after 01.04.2021 should be deemed as issued under Section 148A as substituted by Finance Act, 2021, and treated as show-cause notices to proceed under substituted provisions (paras (!) - (!) ). - It directs that assessing officers provide information/material relied upon within 30 days and allow replies within two weeks, with further steps under Section 148A(d) and (b) following the substituted regime (paras (!) - (!) , (!) - (!) ). - It grants dispensation from prior approval for conducting enquiries as a one-time measure for notices issued under unamended Section 148 after 01.04.2021, and emphasizes that safeguards remain, with rights and defences preserved under Finance Act, 2021 (paras (!) - (!) , (!) - (!) ). - The decision uses Article 142 of the Constitution to settle PAN-India: it modifies and substitutes the Allahabad High Court judgment and applies across other High Courts to avoid ~9,000+ pending appeals, ensuring uniform application of substituted provisions (paras (!) - (!) , (!) - (!) ).

How to apply the substituted provisions of Sections 147 to 151 of the IT Act (Finance Act, 2021) to reassessment notices issued under unamended Section 148 after 01.04.2021?

What is the guidance on treating reassessment notices issued under unamended Section 148 as notices under Section 148A and proceeding with reassessment under the substituted provisions?

What is the scope of Article 142 of the Constitution of India in modifying and pan-India applying the High Court judgments on reassessment notices post-01.04.2021?