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2026 (10) TMI 185

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....Income Tax<br>THE HON&#39;BLE MR. SUSHRUT ARVIND DHARMADHIKARI, CHIEF JUSTICE AND THE HON&#39;BLE MR. JUSTICE G. ARUL MURUGAN For the Appellant : Mr. Allwin Godwin and Mr. Rahul Yadav For the Respondents : Mr. Avinash Krishnan Ravi Junior Standing Counsel for R-1 JUDGMENT (Judgment of the Court was delivered by the Hon&#39;ble Chief Justice) The present appeal is directed against th....

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....ors.). Vide judgment dated 16.07.2026, the writ appeal was allowed on the ground that when the first notice was issued on 12.04.2021 and the subsequent notice under Section 148A(b) was issued on 31.03.2022 culminating in the order dated 02.05.2022 and since all these steps pertaining to the Assessment Year 2015-16 were taken well after the cut-off date of 01.04.2021, the entire re-assessment exerc....

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....ents were comprehensively examined by the Supreme Court in Union of India v. Rajeev Bansal (2024 SCC Online SC 2693). He drew our attention to paragraph 19(f) of the decision in Rajeev Bansal (supra), wherein the Supreme Court explicitly recorded the stance of the Revenue regarding the specific timeline applicable to the Assessment Year 2015-2016. It was acknowledged that for the Assessment Year 2....

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.... order dated 2.5.2022. Since all these steps pertaining to the Assessment Year 2015-2016 were taken well after the cut-off date of 1.4.2021, the entire reassessment exercise is clearly out of time and completely unsustainable in law. 6. As a sequel, the appeal is allowed. The impugned order passed by the learned Single Judge dated 3.6.2026 is set aside. The notices dated 12.4.2021 and 31.....