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2025 (5) TMI 2275
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....aritosh Jain, Mr Divyansh Jain and Mr Abhishek Jain, Advocates. For the Respondent Through: Mr Gaurav Gupta, SSC, Mr Shivendra Singh and Mr Yojit Pareek, JSCs. ORDER 1. The petitioner has filed the present petition, inter alia, impugning a notice dated 31.03.2024 [impugned notice] issued under Section 148 of the Income Tax Act, 1961 [the Act] for the Assessment Year [AY] 2016-17. 2. Th....
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....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 and before only if the time limit for issuance o....
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....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 present case, the period of six years from the end of the rele....