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2023 (4) TMI 1270
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....ma - Advocate for respondents through Video conferencing. ORDER Challenge herein is to the notice under Section 148 (P-1) as well as the order under Section 148 A (d)(P-2) of the amended Income Tax Act, 1961. Learned counsel for petitioner referring to the decision of Apex Court in Union of India and others vs. Ashish Agarwal rendered on 04.05.2022 reported in (2022) 326 CTR (SC) 473, in ....
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....ped assessment amounts to or is likely to amount to fifty lakh rupees or more for that year. Provided that no notice under section 148 shall be issued at any time in a case for the relevant assessment year beginning on or before 1st day of April, 2021, if such notice could not have been issued at that time on account of being beyond the time limit specified under the provisions of clause ....
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....ion of any court, shall be excluded: Provided also that where immediately after the exclusion of the period referred to in the immediately preceding proviso, the period of limitation available to the Assessing Of icer for passing an order under clause (d) of section 148A is less than seven days, such remaining period shall be extended to seven days and the period of limitation under this ....
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.... similar notices u/S.148 and order under 148A(d) of the amended Income Tax Act. Learned counsel for the Revenue Shri Siddharth Sharma is unable to satisfy this Court on the question as to whether an order could be issued u/S.148A(d) and, thereafter a notice u/S. 148 of the amended Income Tax Act when quantum of income which escaped assessment is alleged to be less than 50 lacs. Shri Sharma, how....