2024 (3) TMI 1376

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....ka with Mr. Rohan Chatter. For the Respondent : Mr. Sarvesh Jain. ORDER 1. Heard on the prayer for stay. 2. Learned counsel for the petitioner argued that initiation of re-assessment proceedings by issuance of impugned notice under Section 148 of the Income Tax Act, 1961 (for short, 'the Act'), are time barred and, therefore, without jurisdiction. He would submit that though number of ....

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....yond the time limit specified under the provisions of clause (b) of sub- Section (1) of Section 149, or Section 153A or Section 153C, as the case may be, as they stood immediately before the commencement of the Finance Act, 2021. 3. Relying upon the order dated 24.03.2021 of the Madras High Court in the case of A.R. Safiullah vs. The Assistant Commissioner of Income Tax, Central, Circle-1, Tric....

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....barred thereunder. He would submit that if the proceedings would have been initiated prior to the commencement of the Finance Act, 2021 i.e. before 01.04.2021, it would have been within limitation, as provided under Section 149, as it existed prior to coming into force of Finance Act, 2021. He would further submit that the material which has been found in the search carried out in the premises of ....