CBDT has issued Instruction No. 01/2022, dated 11.5.2022, containing Guidelines for Implementation of SC Judgement in the case of ‘Union of India vs Ashish Agarwal (2022 SCC Online SC 543), dated 4.5.2022. For ready reference of our Readers, the said CBDT Instruction is enclosed as per PDF File at the end of this Article. 

In the said Instruction, CBDT has prescribed a uniform procedure to be adopted for implementing the SC judgement, where extended reassessment notices have been issued, irrespective of the fact, whether such notices have been challenged or not.

Para 6.2 of the said CBDT Instruction, perhaps, constitutes the core of this Instruction, as it specifies the manner, in which, the impugned re-assessment .