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2023 (2) TMI 1172 - DELHI HIGH COURTReopening of assessment u/s 147 - validity of Order passed u/s 148A(d) and notice u/s 148 - period of limitation - HELD THAT:- The record shows that the impugned notice was sent by e-mail to the Petitioner at 12:11 A.M. on 16.07.2021 on the e-mail ID: shashigargca@gmail.com. It cannot but be accepted by the respondent/revenue that even though the notice is dated 30.06.2021, the e-mail that has been placed on record evidencing service of the impugned notice, bears a date and time stamp: 16.07.2021 at 12:11 A.M. No other document establishing delivery of the impugned notice on any date prior to 16.07.2021 has been placed on record by the respondent/revenue. We agree with learned Counsel for the petitioner/assessee, that the impugned notice is barred by limitation and is contrary the view taken by the Court in Suman Jeet Agarwal case [2022 (9) TMI 1384 - DELHI HIGH COURT] and Vinayak Services case [2022 (12) TMI 1424 - DELHI HIGH COURT]
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