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2022 (9) TMI 591 - RAJASTHAN HIGH COURTReopening of assessment u/s 147 - initiation of proceedings u/s 148 - scope of amendment with effect from 01.02.2021, proceedings under Section 148 could not be initiated without first drawing proceedings u/s 148A - HELD THAT:- This Court had protected the petitioner taking into consideration that the notice under Section 148 of the Act was digitally signed only on 02.04.2021. The Hon'ble Supreme Court by its authoritative pronouncement in the case of Union of India & Others Vs. Ashish Agarwal [2022 (5) TMI 240 - SUPREME COURT] We find that the department has proceeded to pass the order u/s 148A(d) against the petitioner. In these changed circumstances, particularly taking into consideration the scope and ambit of the pending petition, we are inclined to close this writ petition also, however, giving liberty to the petitioner to challenge order passed u/s 148A(d) of the Act on such grounds as may be available to the petitioner under the law.
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