2024 (10) TMI 1751

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....na Kanta Sharma For the Petitioner : Mr. Ajay Wadhwa, Ms. Ragini Handa And Mr. Ujjwal Jain, Advocates For the Respondents : Mr. Shlok Chandra, SSC with Ms. Naincy Jain And Ms. Madhavi Shukla, JSCs And Mr. Sushant Pandey, Advocate ORDER 1. The petitioner has filed the present petition impugning a notice dated 31.08.2024 (hereafter the impugned notice) issued under Section 148 of the Inc....

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....e issued at any time for an assessment year beginning on or before 1 April 2021; (ii) if it is barred at the time when the notice is sought to be issued because of the "time limits specified under the provisions of" 149(1)(b) of the old regime. Thus, a notice could be issued under Section 148 of the new regime for assessment year 2021-2022 and before only if the time limit for issuance of....

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....ithout the proviso to Section 149(1)(b) of the new regime, the Revenue could have had the power to reopen assessments for the year 2012-2013 if the escaped assessment amounted to Rupees fifty lakhs or more. The proviso limits the retrospective operation of Section 149(1)(b) to protect the interests of the assesses." 4. In the present case, the period of six years for the relevant assessment yea....