2022 (11) TMI 138

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....23 of 2021 pertains to the AY 2015-16, W.P.(C) No.38822 of 2021 pertains to the AY 2016-17. As far as the AY 2015-16 is concerned, initially a notice dated 31st March, 2021 was issued seeking to reopen the assessment for the AY 2015-16. This was after the expiry of four years from the end of the relevant AY. The notice recorded that it was being issued "after obtaining the necessary satisfaction of the Additional CIT, Range-1, Bhubaneswar". 3. As far as the AY 2016-17 is concerned, a similar notice dated 31st March, 2021 was issued again recording the necessary satisfaction of the Additional CIT, Range-1, Bhubaneswar. 4. Sections 147 to 151 of the Act stood amended by virtue of the Finance Act, 2021 with effect from 1st April, 2021. Follo....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ce is made to the notification dated 31st March, 2021 issued by the Central Board of Direct Taxes (CBDT), extending the time limit for issuance of notice under Section 148 of the Act to 30th April, 2021 in the first instance and by a further notification dated 27th April, 2021 to 30th June, 2021. Accordingly, it is sought to be contended that the question of applicability of Section 148-A of the Act would not arise, because in terms of the CBDT notification dated 31st March, 2021 under the 2020 Act, the time for issuance of the original notice has itself been extended. Reliance is also placed on the following Explanation added by the CBDT notification dated 27th July, 2021 to contend that it is the pre-amended Sections 148, 149 and 151 whic....