Court sets timelines for submissions, restrains actions on notices. Emphasizes statutory compliance and stay implications.

The court directed the respondents to file an affidavit-in-opposition within six weeks and allowed the petitioners to file a reply within two weeks thereafter. The matter was listed for "Final Hearing" after eight weeks. Meanwhile, the respondents were restrained from taking further action based on the impugned notices dated 29th May, 2021, and 18th June, 2021. The judgment emphasizes the importance of complying with statutory obligations before issuing notices under Section 148 of the Income Tax Act, 1961, and the significance of court decisions where non-compliance with Section 148A provisions resulted in the stay of impugned notices.

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Issues:
Challenging impugned notices under Section 148 of the Income Tax Act, 1961 for assessment years 2014-15 and 2015-16. Constitutional validity of The Taxation And Other Laws (Relaxation And Amendment of Certain Provisions) Act, 2020.

Analysis:
The petitioners challenged the impugned notices dated 29th May, 2021, and 18th June, 2021, related to assessment years 2014-15 and 2015-16 under Section 148 of the Income Tax Act, 1961. They contended that the Assessing Officer did not comply with the mandatory provisions of Section 148A of the Act before issuing the notices. Additionally, the constitutional validity of The Taxation And Other Laws (Relaxation And Amendment of Certain Provisions) Act, 2020, was also challenged.

The petitioner's counsel relied on various court decisions to support their contention. They referred to unreported decisions of the Bombay High Court and the Delhi High Court, where impugned notices under Section 148 were stayed due to non-compliance with Section 148A provisions. The counsel for the respondents sought an adjournment and failed to provide any clarification on whether Section 148A provisions were adhered to before issuing the notice in this case.

In light of the submissions, the court directed the respondents to file an affidavit-in-opposition within six weeks and allowed the petitioners to file a reply within two weeks thereafter. The matter was listed for "Final Hearing" after eight weeks. Meanwhile, the respondents were restrained from taking further action based on the impugned notices dated 29th May, 2021, and 18th June, 2021.

This judgment highlights the importance of complying with statutory obligations before issuing notices under Section 148 of the Income Tax Act, 1961. It also underscores the significance of court decisions in similar cases where non-compliance with Section 148A provisions led to the stay of impugned notices. The court's decision to allow both parties to present their arguments and file necessary documents demonstrates a fair and procedural approach to resolving the issues raised in the petition.

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