SC backs validity of 90,000 I-T reassessment notices made after Apr 1, 2021

In a relief to the Income Tax Department, the Supreme Court has upheld the validity of nearly 90,000 reassessment notices issued by the revenue department after April 1, 2021, under old provisions. The top court on Thursday set aside the verdicts of several high courts that had held that the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act (TOLA) of 2021 will not extend the time limit for issuing reassessment notices under the Income Tax Act. TOLA was brought in during the COVID-19 pandemic to extend time limit for income tax compliances. A bench comprising Chief Justice D Y Chandrachud and Justices J B Pardiwala and Manoj Misra dealt with two legal questions related to the interplay of three Parliamentary statutes, the Income Tax Act, the TOLA and the Finance Act. The issues, adjudicated upon by the top court, read: "Whether TOLA and notifications issued under it will also apply to reassessment notices issued after April 1, 2021 and whether the ...