S.148 Income Tax Notice Issued After 31.03.2021 Under Old Regime Invalid Despite TOLA Extension: ITAT

The ITAT (Income Tax Appellate Tribunal) has ruled that an Income Tax notice issued after March 31, 2021, under the old regime is invalid, despite the TOLA (Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act) extension. This critical decision clarifies the transition from the old to the new reassessment regime. While the TOLA Act extended certain deadlines due to the pandemic, the ITAT's ruling implies that notices issued under the old Section 148 after the specified cut-off date (March 31, 2021) are no longer valid, even with the general extensions. This reinforces adherence to the specific procedural changes in reassessment laws.