An instruction dated 11-05-2022 has been issued by the CBDT to implement the Supreme Court of India decision in the case of Union of India vs. Ashish Agarwal.
In the judgement, the Supreme Court of India has held that these extended re-assessment notices issued under the old law shall be deemed to be the show cause notices issued under clause (b) of section 148A of the new law and has directed Assessing Officers to follow the procedure with respect to such notices. It has also held that all the defences available to assessees under section 149 of the new law and whatever rights are available to the Assessing Officer under the new law shall continue to be available.
To view and download the Instruction, click Instruction No. 1-2022
