2025 (3) TMI 1698

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....Mr Sumit Lalchandani, Mr Salil Kapoor, Mr Tarun Chanana, Mr Shivam Yadav and Ms Ananya Kapoor, Advocates. For the Respondents : Mr Vipul Agrawal, senior standing counsel with Ms Sakashi Shairwal and Mr Akshat Singh, Advocates. ORDER 1. The petitioner has filed the present petition, inter alia, impugning a notice dated 29.07.2022 issued under Section 148 of the Income Tax Act, 1961 [the Ac....

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....the Revenue before the Supreme Court. In Union of India & Ors. v. Ashish Agarwal: (2023) 1 SCC 617, the Supreme Court passed directions under Article 142 of the Constitution of India, directing that such notices issued under Section 148 of the Act be construed as the notices under Section 148A(b) of the Act. The AO was also directed to provide the information required to accompany notices under Se....

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....ction 149(1) of the Act is applicable and the AO had a further period of seven days for issuance a notice under Section 148 of the Act. However, the notice was not issued within the said period of seven days; that is on or before 23.06.2022. In view of the above, the present notice has been issued beyond the period of limitation. 6. It is material to note that the AO had also issued another not....