2026 (7) TMI 623

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.... Mr. Akhileshwar Sharma (V.C.), Advocate. P.C. 1. In the above Writ Petition, Rule was issued on 22nd April 2025 and the same was made returnable peremptorily on 30th June 2025, at 2.30 p.m., subject to overnight part heard matters. It appears that due to paucity of time, the matter had not reached and has finally come up for final hearing today. 2. The above Writ Petition is filed seekin....

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....use Notices under Section 148A(b) of the Act. Accordingly, the Notice dated 5th April 2021 was treated as a Show Cause Notice under Section 148A(b) and thereafter the Order dated 28th July 2022 was passed under Section 148A(d). Once the order under Section 148A(d) was passed, a fresh Notice was issued on 29th July 2022. 4. The issue of limitation of these Notices was the subject matter of anoth....

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....nue concedes that for the assessment year 2015-16, all notices issued on or after 1 April 2021 will have to be dropped as they will not fall for completion during the period prescribed under TOLA." 5. In the light of the concession made by the Revenue before the Hon'ble Supreme Court in Rajeev Bansal (Supra), we find that the reassessment proceedings in the present case, pertaining to Assessmen....