2025 (8) TMI 385

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nd/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 impugned assessment order dated 19.05.2023 passed under section 147 r.w.s. 144B of the Act and notice dated 19.05.2023 issued under section 156 of the Act by Respondent No. 2 pursuant thereto in the case of the Petitioner for AY 2015-16 ; B. Issue a writ of and/or order and/or direction in the nature of Prohibition commanding Respondents to forebear from giving effect....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....partment against the order of High Court of Bombay has been dismissed. He has also drawn our attention to the latest order passed by this Court in the case of Mectech knitfabs Pvt. Ltd. vs DCIT Circle 16(1) New Delhi & Anr. [2025 (5) TMI 1967] wherein this Court has in paragraph 11 onwards stated as under:- "11. It is relevant to refer to paragraph 19(e) and 19(f) from the decision of the Supreme Court in Union of India and Ors. v. Rajeev Bansal (supra), which sets out the concession as made on behalf of the Revenue: "e. The Finance Act 2021 substituted the old regime for re-assessment with a new regime. The first proviso to Section 149 does not expressly bar the application of TOLA. Section 3 of TOLA applies to the entire....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... Rajeev Bansal, reported in 2024 SCC OnLine SC 2693, more particularly, paragraph 19(f) which reads thus:- "19. (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 Laws (Relaxation and Amendment of Certain Provisions) Act, 2020." 5. As the revenue made a concession in the aforesaid decision that is for the assessment year 2015-2016, all notices issued on or after 1st April, 2021 will have to be dropped as they would not fall for completion during the period prescribed under the taxation and other laws (Relaxation and Amendment of certain Provisions....