2023 (1) TMI 775

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....nd Mr Udit, Advocates. Respondents: Mr Sunil Agarwal, Sr. Standing Counsel with Mr Tushar Gupta and Mr Utkarsh Tiwari, Advocates. ORDER CM APPL. 54041/2022 1. Allowed, subject to the petitioners filing legible copies of annexures, at least three days before the next date of hearing. W.P.(C) 17045/2022 and CM APPL. 54040/2022 [Application filed on behalf of the petitioner seeking interim relie....

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....ccording to Ms Jha, although the provisions of sub-section (1) of Section 149 of the Act, by virtue of the amendment carried out via Finance Act, 2012 were made retrospective, it will not impact those assessments which had already stand time barred. 2.4 In support of this submission, Ms Jha relies upon a judgment of the coordinate bench of this Court rendered in Brahm Dutt v. ACIT [2019] 260 Taxm....

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....ed only on 31.03.2021, but because of the intercession of Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, the same stood extended further. 7.1 We may note, that Ms Jha, in rejoinder, says that by virtue of Finance Act, 2021, the maximum timeframe under Section 149 of the Act has been reduced to ten years. 8. This is a matter which would require examination qua....