2025 (4) TMI 88

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....AL) 1. The petitioner has filed the present petition, inter alia, praying as under:- "A. Issue a writ of and/or order and or directions in the nature of certiorari or any other appropriate writ, order, or direction quashing impugned notice dated 30.07.2022 issued under Section 148 of the Act and the impugned order dated 30.07.2022 passed under Section 148A(d) of the Act and the notice issued under Section 148A (b) of the Act dated 02.06.2022 by the Respondent No. 1 and the proceedings initiated pursuant thereto; B. Issue a writ of and/or order and/or direction in the nature of Prohibition commanding Respondent No. 1 to forebear from giving effect to and/or taking any step whatsoever pursuant to and/ or in furtherance of....

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....ssued directions for considering the notices issued under Section 148 of the Act as notices issued under Section 148A (b) of the Act and directed the AO to furnish such material and information to the assessees as were required to accompany a notice under Section 148A (b) of the Act. 6. In compliance with the directions issued in Union of India & Others v. Ashish Agarwal (supra), the AO provided information and material to the Assessee by issuing a fresh notice under Section 148A (b) of the Act on 02.06.2022. The Assessee was granted time to respond to the said notice till 27.06.2022. The Assessee responded to the notice dated 02.06.2022 by a letter dated 25.06.2022. 7. The AO passed an order under Section 148A(d) of the Act on 30.07.....

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.... Limitation read with TOLA for (2) (3) Within six Years (4) Expiry of Limitation read with TOLA for (4) (5) 2013-2014 31.03.2017 TOLA not applicable 31.03.2020 30.06.2021 2014-2015 31.03.2018 TOLA not applicable 31.03.2021 30.06.2021 2015-2016 31.03.2019 TOLA not applicable 31.03.2022 TOLA not applicable 2016-2017 31.03.2020 30.06.2021 31.03.2023 TOLA not applicable 2017-2018 31.03.2021 30.06.2021 31.03.2024 TOLA not applicable (f) The Revenue concedes that for the assessment year 2015-2016, all notices issued on or after April 1, 2021 will have to be dropped as they will not fall for completion during the period prescribed under the Taxation and other....