In May 2022, the court had delivered a similar judgment in an appeal by an individual (Ashish Agarwal) and has now extended the verdict to all the assessment notices. The new reassessment law had capped the period for issuing notices with respect to reopening past cases at three years, down from six years earlier.
Even as the new regime kicked in on April 1, 2021, the tax department had issued over 90,000 notices between April 1 and June 30, 2021, for earlier years under the old regime. This created an unprecedented situation when both the old and new reassessment regimes were in force for April-June 2021.
The notices were based on the government's notification extending the time limit to June 30, 2021, citing pandemic-related disruption.
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