2025 (8) TMI 1741

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.... Divya Suri, Advocate. For the Respondents-Income Tax Department : Mr. Saurabh Kapoor, Sr. Standing Counsel, Mr. Rana Gurtej Singh, Jr. Standing Counsel, Ms. Muskaan Gupta, Advocate. ORDER 1. Challenge in the present petition is to notice dated 18.03.2025 issued under Section 148 of the Income Tax Act, 1961 (for short 'Act 1961°), for the Assessment Year 2021-2022 and all subsequent p....

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....dents has also not disputed the same. 4. We have heard learned counsel for the parties and perused the file with their able assistance. 5. Co-ordinate Bench of this Court in Jatinder Singh Bhangu's case (supra) and Jasjit Singh's case (supra), allowed the writ petitions on the same issue, as raised in the present writ petition, by granting liberty to the revenue to follow the procedure as la....

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....he respondents are heavily placing reliance upon office memorandum and letter issued by departmental authorities. It is axiomatic in tax jurisprudence that circulars, instructions and letters issued by Board or any other authority cannot override statutory provisions. The circulars are binding upon authorities and Courts are not bound by circulars. The mandate of Section 144B, 151A readwith notifi....