2022 (7) TMI 1459

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....ents : Mr. Ashok Kotangle a/w Mr. P. A. Narayanan, Mr. Prabhakar Ranshur & Mr. Ajay V. Anand, Advocate. ORDER P.C.: Reply has not been filed by the Respondents. However, with the consent of learned Counsel for the parties, the matter is taken up for final disposal at this stage. 2. The Petitioner challenges the impugned notice dated 29th March, 2021, issued under Section 148 of the Inc....

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.... it is clear that a notice under Section 148 of the Act, 1961 cannot be issued after the expiry of period of four years from the end of the relevant assessment year, unless the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner was satisfied, on the reasons recorded by the A.O., that it was a ft case for the issue of such a notice. In the present case, ....