Commissioner of Income Tax : (International Taxation)-2, Mumbai I74Ploor, Room No. 1706, Air India Building, Nariman Point, Mumbai 400021. Tel No, 022-22027605 (s/2021-22 Dated: 02.02.2022 [ No: CIT(T)-2, To, All the Assessing Officers in the charge of CIT (17) - 2, Mumbai The Addl. CIT (IT) Rg. 2(1), 2(2) and 2/3), Mumbai Sub.: Time limit for completion of reopened assessments u/s 148 of the IT Act ~ reg. ‘The assessments in several cases were reopened during the period 01.04.2021 to 30.06.2021, and the same are pending for completion. The notices for reopening in these cases were getting barred by limitation on 31.03.2021 However, under the Taxation and Other Laws (Relaxation and Amendment of Certain provisions) Act, 2020 (“TOLA”) passed by Parliament on 29.9.20 and in view of Notification No. 20/2021 dated 31.03.2021 and Notification No. 38/2021 dated 27.04.2021, the period for issuance of notices u/s 148 was extended to first 30.4.2021 and then 30.06.2021. The notices issued u/s 148 as per the extended date has been challenged by way of Writ Petitions in several High Courts and many High Courts have quashed such notices, including Hon'ble Allahabad High Court. An SLP has been preferred against the decision of the Hon’ble Allahabad High Court. ‘The contention of the department is that the extension notified under “TOLA” applies to the provisions of law as it stood on 31.03.2021 and only the time limits were extended. In the light of the above, though the time barring date appearing in ITBA in respect of notices issued in the current Financial Year 30.06.2021 isshown as 31.03.2023, based on Section 153(2) of the IT Act, considering the fact, that the extension in the time period for issue of notices is based on the provisions of law as it stood as on 31.03.2021, it is possible that plea may be taken by the assessee before the higher appellate authorities later, that the assessment should have been completed by 31.03.2022. It is, therefore, directed that all such reopened assessments should be completed before 31.03.2022, treating the same as applicable time barring date for such reopened assessments, (SANJAY SINGH) Commissioner of Income Tax (IT)-2, Mumbai. ‘This must be strictly complied with. Copy t. The Chief Commissioner of Income-tax (IT) WZ, Mumbai, for information. CIT(IT) - 2, Mumbai.