Faceless Tax Assessment Deadline Dispute: Section 144B Deadline Expired; Notification No.74/2021 Exclusion of Section 144C(13) Questioned.

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....Faceless assessment u/s 144B - time-limit to complete the assessment - Even if for a moment we hold that Relaxation Act is applicable to petitioner’s case, the time-limit provided by Notification No.38/2021 expired on 30th June 2021. Notification No.74/2021, on which respondents have relied upon to submit that time has been extended upto 30th September 2021, specifically excludes Section 144C(13) of the Act. If that also was to be included, Notification No.74/2021 would have expressly provided for it as it has provided in Notifications No.20/2021 and 38/2021. - HC....