2022 (5) TMI 1467

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....Respondent : Mr. T.K. Satapathy, Senior Standing Counsel for IT Department ORDER 1. The Court has been shown the Judgment dated 4th May 2022, passed by the Supreme Court of India in Civil Appeal No.3005 of 2022 and batch (Union of India & others v. Ashish Agarwal), where the issue taken up for consideration was the correctness of the orders passed by the High Courts of Delhi, Rajasthan, Calc....

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....assed by different High Courts on the issue and under which similar notices which were issued after 01.04.2021 issued under section 148 of the Act are set aside and shall be governed by the present order and shall stand modified to the aforesaid extent. The present order is passed in exercise of powers under Article 142 of the Constitution of India so as to avoid any further appeals by the Revenue....

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....sent case, the notice under Section 148 of the Act pertaining to the Assessment Year (AY) 2013-14 was issued on 30th March 2021, i.e., prior to 1st April 2021. Also, it was beyond the period of six years after the expiry of the AY in question. Consequently, both in light of the Judgment of the Supreme Court in Union of India & others v. Ashish Agarwal (supra) and the Order of this Court dated 24th....