2024 (3) TMI 1375

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....ya For the Petitioner : Mr. Prakul Khurana with Ms. Vrinda Lakhotia. For Respondent : Mr. Siddharth Bapna with 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, with....

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....not have been issued at that time on account of being beyond 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 Assista....

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....Section 148 of the Act is within limitation and not 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....