2025 (11) TMI 227

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....Shri Somnath Ghosh, AR For the Revenue : Shri S.B. Chakraborthy, DR ORDER PER RAJESH KUMAR, AM: This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the "Ld. CIT(A)"] dated 12.03.2025 for the AY 2015-16. 02. At the outset, the ld. Counsel for the assessee submitted that the notice issued u/s 148 of th....

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....cause notice in terms of Section 148A(b) of the Act. Thereafter, order u/s 148A(d) was passed on 29.07.2022 and notice u/s 148 of the Act was issued on 29.07.2022. 04. The Ld. Counsel vehemently submitted before us that the notice issued u/s. 148 of the act is barred by limitation as benefit of TOLA is not available to the assessment year 2015-16. The assessee relied on in defense of his argume....

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....023 vide its order dated 27.01.2025 has taken the similar view. The Ld. AR, therefore, prayed that the same may kindly be quashed. 05. After hearing the rival contentions and perusing the material available on record, we find that undisputedly, the notice u/s. 148 of the Act was issued on 29.07.2022 which falls beyond the period of limitation as the relaxation granted by TOLA w.e.f. 01.04.2021 ....