The provisions of Article 120, paragraph (3) of the new Income Tax Act (including as applied mutatis mutandis pursuant to Article 122, paragraph (3), Article 123, paragraph (3), Article 125, paragraph (4) and Article 127, paragraph (4) of the new Income Tax Act (including as those provisions are applied mutatis mutandis pursuant to Article 166 of the new Income Tax Act) and pursuant to Article 166) apply in the case where a Tax Return is filed on or after the effective date, and the provisions then in force continue to govern in the case where a Tax Return was filed before the effective date.