2024 (6) TMI 694

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....ion has been filed, inter alia, questioning the jurisdiction and/or authority of the jurisdictional officer to issue the notice dated 26th April, 2023 under Section 148 of the Income Tax Act, 1961 as amended by Finance Act, 2021, (hereinafter referred to as the "said Act"). 2. Mr. Shraff, learned advocate representing the petitioner, by placing before this Court the first and the fifth proviso to....

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....to the aforesaid notice dated 29th March, 2021 and the same having already been concluded by passing the assessment order dated 30th March, 2022 read with Sections 144 and 147 of the said Act, no further notice under Section 148 of the said Act, in respect of the selfsame assessment year could have been issued on the petitioner. In support of his contention he has placed reliance on a judgment del....