2025 (6) TMI 1142

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....eep Goel, Advs. For the Respondent : Mr. Indruj Singh Rai, Mr. Sanjeev Menon, Mr. Rahul Singh & Mr. Gaurav Kumar, Advs. ORDER 1. The petitioner [Assessee] has filed the present petition, inter alia, impugning a notice dated 31.08.2022 [the impugned notice] issued under Section 148 of the Income Tax Act, 1961 [the Act] in respect of the Assessment Year [AY] 2014-15. It is the Assessee's ca....

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....scaped assessment. 3. The Revenue appealed the decisions rendered by various High Courts to the Supreme Court of India. In Union of India v. Ashish Agarwal: 2022 SCC OnLine SC 543 - which was one of such appeals arising from the decision of the Allahabad High Court - the Supreme Court delivered its decision on 04.05.2022, whereby it concurred with the view that the amended provisions which came....

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....th the directions issued by the Supreme Court in the case of Union of India & Ors. v. Ashish Agarwal (supra), the Assessing Officer [AO] provided information and material to the Assessee on 30.05.2022. The Assessee was granted two weeks' time to respond to the said notice. The Assessee responded to the notice dated 30.05.2022 on 11.06.2022. 5. The AO passed an order under Section 148A(d) of the....

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....(b) of the Act by virtue of the decision of the Supreme Court in Union of India & Ors. v. Ashish Agarwal (supra). The Supreme Court also granted further time to provide the material, which was required to accompany such notice. As explained by the Supreme Court in the case of Union of India v. Rajeev Bansal: 2024 SCC OnLine SC 2693, the period from the date of the issuance of the notice till 04.05....