(1.) Learned counsel for the petitioner has drawn our attention to Annexure P/1, which is a notice issued by the Department U/s.148 of the Income Tax Act, 1961 on 29/6/2021 (Annex.P/1). Learned counsel for the petitioner has submitted that the Finance Act, 2021, which was notified on 1/4/2021, has by Sec. 41 and 42, has amended Sec. 148 of the Income Tax Act (for short 'I.T. Act") and inserted Sec. 148-A where, for the purpose of re-opening assessment, the procedure U/s.148-A has to be mandatorily followed, providing an opportunity to the petitioner in this case of being heard and also required the prior approval of the specified authority.