2025 (5) TMI 2273

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....ioner Through: Mr. Gaurav Jain, Mr. Shubham Gupta, Ms. Shalini, Advocates. For the Respondent Through: None. ORDER 1. The petitioner has filed the present petition, inter alia, impugning a notice dated 28.02.2025 [impugned notice] issued under Section 148 of the Income Tax Act, 1961 [the Act] for the Assessment Year [AY] 2017-18. 2. The petitioner also impugns the order dated 28.02.202....

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....fore 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 such notice continued to exist under Section 149(1)(b) of the....

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....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 present case, the period of six years from the end of the relevant AY 2017-18 expired on 31.03.2024. The impugned no....