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The HC, addressing validity of reopening under the IT Act read with TOLA, accepted Revenue's concession that all s.148 notices issued after 1 April 2021 for AY 2015-16 would be withdrawn; accordingly the s.148 notice dated 5 April 2022 and the consequential reassessment order, demand, penalty and recovery notices are quashed and set aside. The Petitioner undertakes to withdraw the appeal before the CIT(A) within two weeks, and that undertaking is accepted. The court ordered that if the Revenue successfully challenges and obtains vacation of the present order, the Petitioner's CIT(A) appeal will automatically revive and proceed on merits in accordance with law.
The HC, addressing validity of reopening under the IT Act read with TOLA, accepted Revenue's concession that all s.148 notices issued after 1 April 2021 for AY 2015-16 would be withdrawn; accordingly the s.148 notice dated 5 April 2022 and the consequential reassessment order, demand, penalty and recovery notices are quashed and set aside. The Petitioner undertakes to withdraw the appeal before the CIT(A) within two weeks, and that undertaking is accepted. The court ordered that if the Revenue successfully challenges and obtains vacation of the present order, the Petitioner's CIT(A) appeal will automatically revive and proceed on merits in accordance with law.
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