2022 (8) TMI 140

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....E MR. JUSTICE GOPINATH P. FOR THE PETITIONER : BY ADVS. LATHA ANAND M.N.RADHAKRISHNA MENON S.VISHNU (ARIKKATTIL) FOR THE RESPONDENT : BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT JUDGMENT [ WP(C) Nos. 26171/2021 , 17655/2021, 26860/2021 ] The petitioners in these cases were issued with notices under Section 148 of the Income Tax Act. The petitioners have approached this Court s....

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....is/are hereby modified and substituted as under:- "(i) The impugned section 148 notices issued to the respective Assessees which were issued under unamended section 148 of the IT Act, which were the subject matter of writ petitions before the various respective High Courts shall be deemed to have been issued under section 148 of the IT Act as substituted by the Finance Act, 2021 and const....

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....e concerned Assessing Officers to hold any enquiry, if required; (iii) The assessing officers shall thereafter pass orders in terms of section 148A(d) in respect of each of the concerned Assessees; Thereafter after following the procedure as required under section 148A may issue notice under section 148 (as substituted); All defences which may be available to the assesses includi....