Bench: The Ld. Cit(A). The Ld. Cit(A), After Calling For A Remand Report Under Rule 46A, Recorded The Following Findings (Para 5.1 To 5.5 Of The Appellate Order):
147 to 153, in relation to both reopening u/s 148 and making reassessment, thus reassessment was bad in law and in procedure. 3. That notice u/s 148 dated 31.03.2021 was issued on 01.04.2021, therefore it would be governed by the re-assessment regime which came into effect on 01.04.2021, thus, assessment is not according to new procedure established