2025 (8) TMI 1740

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....IT Sr.DR ORDER PER RAJ PAL YADAV, VP: The assessee is in appeal before the Tribunal against the order of the ld. Commissioner of Income Tax (Appeals) [in short 'the CIT (A)'] dated 20.12.2024 passed in assessment year 2015-16. 2. The assessee has pleaded an additional ground of appeal whereby he has contended that notice u/s 148A(d) of the Act was issued on 31.03.2022 by jurisdictional....

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.... "6. We have duly considered the rival contentions and gone through the record carefully. Admittedly, notice under Section 148 was issued after the Notification issued by the Ministry of Finance, Government of India on 29.03.2022. The notice under Section 148 has been issued on 29.03.2023 i.e. almost one year from the Notification. Thus, facts of other year are squarely applicable. The issue....

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.... reliance on the following two judgments of this Court:- i. CWP-15745-2024, titled Jatinder Singh Bhangu Vs. Union of India and others, decided on 19.07.2024; and ii. CWP-21509-2023, titled Jasjit Singh Vs. Union of India and others, decided on 29.07.2024. 3. Learned counsel for the respondents does not dispute the fact that the case of the petitioner is covered in his f....

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....d of appeal of Cross Objection and hold that notice issued under Section 148 of the Income Tax Act in assessment year 2019-20 is bad in the eyes of law. It was without jurisdiction. Accordingly, re-assessment order is quashed." 5. Apart from this order, there are large number of judgements at the end of the Jurisdictional High Court including in the case of Disha Gupta (supra). 6. Respectful....