2025 (11) TMI 280

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....i 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 09.12.2024 for the AY 2015-16. 02. At the outset, the ld. Counsel for the assessee submitted that the notice issued u/s 148 of the Act on 23.06.2021 is barred by limitation in ....

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.... 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 23.06.2021. 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 arguments on the decision of H....

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.... 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 23.06.2021 which falls beyond the period of limitation as the relaxation granted by TOLA w.e.f. 01.04.2021 to 30.06.2021 is not ava....