2025 (10) TMI 591

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....ppropriate order/ direction/ writ of Certiorari to call for the records relating to the impugned notice dated 31.08.2024 issued under section 148 of the Act (Annexure P-1) by the Respondent No. 1 for AY 2015-16 and quash the same for being illegal and without jurisdiction; (B) Pass an appropriate order/ direction I writ of Certiorari to call for the records relating to the impugned order dated 31.08.2024 issued under section 148A(d) of the Act (Annexure P-2) by the respondent no. 1 for AY 2015-16 and quash the same for being illegal and without jurisdiction;" 4. Mr. Anmol Jagga, learned counsel for the petitioner submits that the petitioner in writ petition is challenging the order passed under Section 148A(d) of Income Tax Act,....

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....d, he states that, as per his information no SLP has been filed against the same. 8. Mr. Siddhartha Sinha, learned Senior Standing Counsel for the respondent states that he cannot confirm this aspect. 9. Mr. Sinha has not shown anything contrary to the judgment of this Court in Manju Somani (supra), more particularly Paragraph 12 onwards, which reads as under: "12. As is manifest from the above, the Proviso to Section 149 clearly bids us to go back in point of time and examine whether a proposed reassessment pertaining to a period prior to 01 April 2021 would sustain based on the time frames as they existed prior to the promulgation of Finance Act, 2021. The Proviso embodies a negative command restraining the respondents from....