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of <h1>Section 148 notice and section 148A(d) order time-barred; first proviso to section 149(1) and TOLA Act ineffective</h1> <h3>DHARA VARUN SHAH Versus INCOME TAX OFFICER</h3> DHARA VARUN SHAH Versus INCOME TAX OFFICER - TMI Petition under Article 226 challenged notice under section 148 and order under section 148A(d) dated 29.08.2022 for Assessment Year 2014-15. Relying on the Court's decision in Keenara Industries (and allied matters), and on the ground of limitation, the petition was allowed. The court held the impugned notice u/s. 148 and the impugned order u/s. 148A(d) dated 29.08.2022 'are quashed and set aside' for AY 2014-15. Interim relief and delay analysis were governed by the cited precedent addressing reopening beyond limitation. Additionally, the court permitted service of process by e-mode on the official email address in addition to regular service. Costs and other ancillary prayers were addressed by the order in favour of the petitioner.
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