2024 (10) TMI 1708

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....ner Through: Mr Gaurav Jain with Mr Shubham Gupta and Ms Shalini, Advocates. For the Respondent Through: Mr Anurag Ojha, Sr. Standing Counsel with Ms Hemlata Rawat and Mr V.K. Saksena, Advocates. ORDER PER 1. The petitioner has filed the present petition, inter alia, impugning an order dated 30.08.2024 (hereafter the impugned order) issued under Section 148A(d) of the Income Tax Act, 1961....

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....s as follows: (i) no notice under Section 148 of the new regime can be issued at any time for 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 f....