2024 (12) TMI 1562

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..... Sakshi Rustagi and Ms. Sakshi Srivastava, Advocates. For the Respondent : Mr. Siddhartha Sinha, Senior Standing Counsel with Ms. Anu Priya Nisha Minz, Advocate. ORDER 1. The petitioner has filed the present petition, inter alia, impugning a notice dated 16.10.2024 (hereafter the impugned notice) issued under Section 148 of the Income Tax Act, 1961 (hereafter the Act) for the assessment year (....

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....r 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 regime for assessment year 2021-2022 and before only if the time limit for issuance of such notice continued to exist ....

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....d under Section 149(1)(b) of the new regime applies prospectively. For example, for the assessment year 2012-2013, the ten year period would have expired on 31 March 2023, while the six year period expired on 31 March 2019. Without the proviso to Section 149(1)(b) of the new regime, the Revenue could have had the power to reopen assessments for the year 2012-2013 if the escaped assessment amounted....