2022 (8) TMI 1316

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....upta, Junior Standing Counsel for respondents No.2 and 3. ORDER Challenge in the instant petition is to notice dated 13.04.2021 (Annexure P-1) pertaining to assessment year 2013-2014; notice dated 17.05.2022 (Annexure P-8) - treating the earlier notice to be under Clause (b) of Section 148-A of the Act; order dated 28.07.2022 (Annexure P-18) passed under Section 148-A(d) of the Income Tax Act ....

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....(b) of the Section as it stood immediately before the commencement of Finance Act 2021 as such in terms of proviso to Section 149 as amended w.e.f. 01.04.2021 since more than 06 years had elapsed from the end of assessment year 2013-2014 on 31.03.2020, the re-assessment notice for assessment year 2013-2014 could not be issued. It is vehemently asserted that the initiation of proceedings by issuan....