2022 (1) TMI 1291

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....[2023] 452 ITR 285 (Ori), 2022 SCC OnLine Ori 4162, (2022) 326 CTR 871<br>ORISSA HIGH COURT - HC (Judgement / Order / Decisions)<br>Dated:- 24-1-2022<br>W. P. (C) No. 20919 of 2021, W. P. (C) No. 21480 of 2021, W. P. (C) No. 24589 of 2021, W. P. (C) No. 39915 of 2021, W. P. (C) No. 41242 of 2021, W. P. (C) No. 41282 of 2021, W. P. (C) No. 1782 of 2022, W. P. (C) No. 1786 of 2022, W. P. (C) No. 41....

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....an Kumar Agarwal Versus DCIT Circle 1(1), Cuttack and Another THE CHIEF JUSTICE S. MISHRA For the Petitioner : Mr. Sidhartha Ray, Advocate, Mr. R.P. Kar, Advocate, Mr. J.M. Pattanaik, Advocate, Mr. Basudev Panda, Sr. Advocate, Mrs. Kananbala Roychoudhury, Advocate For Opposite Parties : Mr. S.S. Mohapatra Senior Standing Counsel, Mr. T.K. Satapathy, Sr. Standing Counsel, Mr. R.S. Chimanka....

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....d is clearly therefore, time barred in terms of the first proviso to Section 147 of the IT Act. 4. The stand of the Revenue that in view of the notifications issued by the Central Government in terms of the provisions of the Taxation and other laws (Relaxation and Amendment of Certain Provisions) Act, 2020, the said time limits stood extended is clearly untenable as those notifications were iss....

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....of their authority, the point involved was that for the purpose of Section 151(1) of the Income Tax Act, 1961since the reopening of the assessment was beyond 4 years, it had to have the prior approval of the Commissioner of Income Tax, and there was no such approval in the present case. 2. Consequently, no ground is made out for reviewing the order dated 20th November, 2019 in W.P.(C) No.....