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2021 (6) TMI 1056 - BOMBAY HIGH COURTValidity of Reopening of assessment u/s 147 - applicability of the newly inserted provisions of Section 148A and the amendments brought inter alia in Section 149 - violation of mandatory provisions for issuance of notice, which have been effective from 1st April, 2021. HELD THAT:- As Petitioner drew our attention to the notice annexed at Exhibit ‘L’ with reference to the provisions of Section 148A of the Act, which requires the assessing officer to conduct the inquiry and also provide an opportunity of being heard, which has not been apparently done. He, therefore, seeks stay of further proceedings in the matter. As Respondent-Revenue submits that she needs time to file reply in the matter, we are inclined to stay the proceedings in connection with notice dated 7th April, 2021 under Section 148 of the Income Tax Act for the assessment year 2013- 2014. Till the next date, there shall be ad-interim stay to the proceedings in connection with notice dated 7th April, 2021.
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