2025 (11) TMI 104

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....iorari or any other appropriate writ, order or direction for quashing: (a) the notice dated 08.06.2021 issued under the erstwhile section 148 and now deemed to be notice under section 148A(b) of the Income Tax Act, 1961 ('the Act'); (b) the letter/ notice dated 24.05.2022 communicating the so called information/ material forming the basis of proceedings under section 148/148A of the Act; (c) the order dated 30.07.2022 passed [with the prior approval of Respondent No.3] under section 148A(d), and the consequent initiation of reassessment proceedings vide notice dated 30.07.2022 issued under section 148 of the Act; in the case of the Petitioner for assessment year 2014-15, and all proceedings/ actions conse....

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....24 SCC OnLine SC 2693, which reads as under:- SUMMARYCHART A. Key Facts: S. No PARTICULARS DATE Relevant Pg./Ann No. 1. Notice issued under section 148 (old regime) 08.06.2021 81/'A' 2. Letter communicating information pursuant to SC decision in Ashish Agarwal - reply to be filed by 07.06.2022 24.05.2022 82/'B' 3. Reply filed by Petitioner 06.06.2022 231/'I' 4. Order u/s 148A(d) 30.07.2022 93/'C' 5. Notice issued u/s 148 - Sanction obtained from CCIT 30.07.2022 101/'D' B. COMPUTATION OF LIMITATION AS PER DECISION OF UOI VS. RAJEEV BANSAL [2024] 301 Taxman 238 (SC): S.No.     SC Paras 1. Assessment Year 2014-15 ....

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....herein we have in paragraphs no.4 to 8 has held as under:- "4. On the other hand, Mr. Debesh Panda, learned counsel appearing for the respondent/Revenue by referring to the judgment of this Court in Kawaljeet Kaur v. Assistant Commissioner of Income Tax Circle (34) 1 Delhi & Ors., W.P.(C) 3908/2023 and connected petitions wherein it was held as under, would urge that the matter be remanded back to the AO to decide the surviving period by passing a reasoned order: "26. Having identified the broad principles which would now govern the question of surviving time, we are of the considered opinion that rather than this Court undertaking the gargantuan exercise of examining individual facts, it would appear to be expedient to fr....