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2023 (4) TMI 1270 - MADHYA PRADESH HIGH COURTReopening of assessment - Time limit for notice u/s 149 - whether an order could be issued u/s.148A(d) and, thereafter a notice u/s. 148 of the amended Income Tax Act when quantum of income which escaped assessment is alleged to be less than 50 lacs? - HELD THAT:- Prima facie it appears that even if the CBDT letter provides otherwise, the same cannot supplant the statutory provision u/s. 149 of the Income Tax Act and therefore, prima facie the petitioner appears to have made out a case for admission and interim relief. Accordingly, as an interim relief, it is directed that the notice u/s 148 of the amended Income Tax Act and the order u/s 148A(d) of the amended Income Tax Act shall remain stayed, till the next date of hearing.
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