2024 (11) TMI 1204

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....MS. JUSTICE SWARANA KANTA SHARMA For the Petitioner: Mr Sameer Rohatgi with Mr Kartikey Singh and Mr Naman Gupta, Advocates For the Respondents: Mr Siddhartha Sinha, Sr. Standing Counsel ORDER 1. Issue notice. 2. Learned counsel appearing for the respondents accepts notice. 3. The petitioner has filed the present petition, inter alia, impugning an order dated 01.05.2024 (hereafter t....

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....be broken down for analysis as follows: (i) no notice under Section 148 of the new regime can be issued at any time for an assessment year beginning on or before 1 April 2021; (ii) if it is barred at the time when the notice is sought to be issued because of the "time limits specified under the provisions of" 149(1)(b) of the old regime. Thus, a notice could be issued under Section 148 of the new ....