Validity of Notice u/s 148 of Income Tax Act must be Evaluated Based on Legal

The Bombay High Court ruled that the validity of a notice under Section 148 of the Income Tax Act must be assessed based on the legal framework in place on the date of issuance. The decision emphasizes that the procedural and substantive legality of such notices depends on the laws applicable at the time they were issued, rather than on future amendments or changes in legislation. This principle ensures that notices are evaluated consistently with the legal standards existing when they were formally issued, maintaining the integrity and predictability of tax enforcement practices.