Supreme Court agrees with the High Courts that Income Tax Department erred in issuing reassessment notices for AYs ending before 31st March, 2021 as per old provisions even after 31st March, 2021 while the government has enacted a complete new set of provisions for reassessment proceedings effective on or after 1st April, 2021. Earlier various High Courts has quashed around 9000 such notices due to the err on the part of revenue.
The Apex Court to strike a balance between the rights of revenue as well as the respective assesses extended partial relief to the revenue by modification and substitution in the orders of HCs as under:
Finally, this SC order shall be applicable PAN India and all judgement and orders passed by different HCs on the issue and on similar noticed issued after 1.4.2021 pending in the various courts.
Thus, the revenue got the right to open more than 90,000 notices may involve income escaped assessment to the tune of around one Lakh Crore.