2026 (10) TMI 287

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....anya Kapoor and Mr. Utkarsa Gupta, Advocates. For the Respondents Through: Mr. Vipul Agrawal SSC with Ms. Sakshi Shairwal, Mr. Akshat Singh, JSCs. JUDGMENT PER DINESH MEHTA, J. (ORAL) 1. By way of present writ petition preferred under Article 226 of the Constitution of India, the petitioner has challenged the notice dated 25.07.2022 under Section 153C of the Income-Tax Act, 1961 (herei....

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..... He, however, submitted that an SLP against the said judgment has been filed before Hon'ble the Supreme Court. 5. Heard learned counsel for the parties. 6. It does not need much discussion that as the satisfaction note was recorded on 16.06.2022, i.e. in the assessment year 2023-24, the notice passed on 25.07.2022 qua assessment year 2016-17 is clearly beyond the limitation period (which sh....