2026 (8) TMI 1195

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....ndhi. For the Respondent/Revenue: Mr. N.C. Ranganayakulu. P.C. : 1. Rule. Respondent waives service. With the consent of parties, Rule made returnable forthwith in the above Writ Petitions and heard finally. 2. The above two Writ Petitions are filed seeking to quash and set aside the notices dated 10th August 2023 issued under Section 153C of the Income Tax Act, 1961 ('the IT Act') and....

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....etitions were allowed on the basis that the Satisfaction Notes dated 3rd August 2023 and 10th August 2023 in those cases were not recorded "immediately", as stipulated by the Hon'ble Supreme Court in the case of Commissioner of Income-tax-III vs. Calcutta Knitwears [(2014) 362 ITR 673 (SC)]. He therefore submitted that, on the basis of the ratio laid down in the Petitioner's own case for Assessmen....

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.... 2021-22. 5. We have heard the learned Counsel appearing for the parties. We have also perused the papers and proceedings in the above two Writ Petitions. For the Assessment Years 2015-16, 2016-17, 2017-18, 2018-19 and 2021-22, this Court has already taken a view in the Petitioner's own case that the notice dated 10th August 2023 issued under Section 153C of the IT Act is time barred as the sam....