2025 (2) TMI 1316

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....R RAO GEDELA For the Petitioner Through: Mr. Ujjwal Jain, M.A. Ansari and Mr. Vinod Kumar, Advocates. For the Respondents Through: Mr. Anurag Ojha, SSC with Ms. Hemlata Rawat and Mr. V.K. Saksena, JSCs. ORDER 1. The petitioner has filed the present petition, inter alia, impugning a notice dated 02.04.2024 (hereafter the impugned notice) issued under Section 148 of the Income Tax Act, 1....

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....notice under Section 148 of the new regime can be 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 a....

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....rch 2023, while the six year period expired on 31 March 2019. Without 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." 5. In the presen....