2025 (9) TMI 1751

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.... of the Act, dated 20/03/2022 bearing DIN No. ITBA/AST/F/148A(SCN)/2021- 22/1041110019(1), issued by the Respondent No.1 for the assessment year 2018-19 herein marked as Annexure - A. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under section 148 of the Act dated 27/04/2022 bearing DIN No. ITBA/AST/S/148_1/2022- 23/1042880981(1) issued by the Respondent No.1 for the assessment year 2018-19 herein marked as Annexure - A1. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order under section 148A(d) of the Act, dated 27/04/2022, bearing DIN No. ITBA/AST/F/148A/2022- 23/1042880971(1) passed by the Respondent No.1 for the ass....

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....sessee] had filed the said petition, inter alia, impugning a notice dated 20.03.2022 issued under Section 148A (b) of the Income Tax Act, 1961 [Act] for the assessment year [AY] 2015-16 on the ground that the said notice did not provide sufficient time for the Assessee to file a response to show cause calling upon him to show cause why it was not a fit case for issuance of a notice under Section 148 of the Act. 3. The learned Single Judge has found merit in the aforesaid contention and accordingly, set aside the impugned notice as well as the notice dated 31.03.2022 issued under Section 148A (d) of the Act and further reassessment proceedings that were initiated pursuant to the said notice. 4. Before proceeding further, it....

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.... one month from the end of the month in which the reply referred to in clause (c) is received by him, or where no such reply is furnished, within one month from the end of the month in which time or extended time allowed to furnish a reply as per clause (b) expires: Provided that the provisions of this section shall not apply in a case where,- (a) a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A in the case of the assessee on or after the 1st day of April, 2021; or (b) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner that any money, bullion, jewellery or other valuable article or ....