2025 (3) TMI 1691

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....vs. For the Respondent : Mr. Debesh Panda, Mr. Vikramaditya Singh & Ms. Zehra Khan, Advs. ORDER 1. The petitioner [Assessee] has filed the present petition, inter alia, impugning a notice dated 29.07.2022 [the impugned notice] issued under Section 148 of the Income Tax Act, 1961 [the Act] in respect of the Assessment Year [AY] 2014-15. It is the Assessee's case that the impugned notice ha....

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.... to supply the material on which such notices were premised. 3. In compliance with the directions issued by the Supreme Court in the case of Union of India & Ors. v. Ashish Agarwal (supra), the Assessing Officer (AO) provided information and material to the Assessee and also issued a fresh notice under Section 148A(b) of the Act on 31.05.2022. The Assessee was granted two weeks' time to respond....

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.....06.2021, which was five days before the expiry of the period of limitation. As noted above, the said notice was deemed to be a notice under Section 148A(b) of the Act. In terms of the Fourth Proviso to Section 149 of the Act, as appliable at the material time, the said period was required to be further extended for a further period of seven days after completion of the procedure under Section 148....

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....iding the material, which should have accompanied a notice under Section 148A(b) of the Act, as well as the time available to the assessee to respond to the said notice was also required to be excluded by virtue of the Third Proviso to Section 149(1) of the Act, as applicable at the material time. 7. In the present case, the said time expired on 14.06.2022. As on that date, the remaining period....