reassessment proceedings would be\ngoverned by the law prevailing prior to 01.04.2021.\n9.\nWe are unable to accept the aforesaid contention of the Revenue. On\nperusal of the above e-mail communication by the revenue, we find that the\ntime of sending of the email is clearly mentioned as 03:53:49 AM on\n01.04.2021, and the time of delivery