The Supreme Court held that the reassessment notices issued under the unamended Section 148 of the Income Tax Act on or after April 1, 2021, will not be deemed to be invalid just because they were issued under the old law. While modifying the relevant orders of various high courts that quashed the reassessment notices issued under the Section after the cut-off date, the SC said that these notices will be deemed as show-cause notices issued to the respective assessees under the new Section 148A of the Act.