(1.) The present batch of appeals involves the interplay of three Parliamentary statutes: the Income Tax Act 1961 ["Income Tax Act"], the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act 2020, ["TOLA"] and the Finance Act 2021. The Income Tax Act was enacted to levy and collect tax on the income of assesses.
(2.) Ss. 147 to 151 deal with the procedure of reassessment. The scheme of reassessment under Ss. 147 to 151 was substantially overhauled by the Finance Act 2021 with effect from 1/4/2021. Under the old regime, Sec. 147 empowered the assessing officer
(3.) Sec. 149