2025 (6) TMI 987

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....itioner Mr. Prithu Dudhoria ... for the respondents ORDER 1. Challenging the issuance of notice under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as the said Act) in respect of the assessment year 2014-2015 dated 27th March, 2025 on the basis of a search conducted under Section 132 of the said Act on 3rd November, 2023, the present writ petition has been filed. 2. ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....essment year relevant to the previous year in which search is conducted or requisition is made which falls beyond six assessment years but not later than ten assessment years from the end of the assessment year relevant to the previous year in which search is conducted or requisition is made. He would submit that the new timeline provided for in Section 149 of the said Act, having regard to the fi....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....year 2015-2016 and not beyond. He submits that the exercise of jurisdiction by the jurisdictional Assessing Officer to issue a notice under Section 148 of the said Act in respect of the assessment year 2014-2015 by virtue of Section 153A(1) of the said Act and the first explanation thereto appears to be in colourable exercise of power, without jurisdiction and barred by limitation. Accordingly, he....