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2022 (5) TMI 1467 - HC - Income TaxReopening of assessment u/s 147 - Scope of amendment by the Finance Act 2021, which introduced the new amended provisions i.e., Sections 147 to 151 with effect from 1st April, 2021 - HELD THAT:- In the present case, the notice under Section 148 of the Act pertaining to the Assessment Year (AY) 2013-14 was issued on 30th March 2021, i.e., prior to 1st April 2021. Also, it was beyond the period of six years after the expiry of the AY in question. Consequently, both in light of the Judgment of the Supreme Court in Union of India & others v. Ashish Agarwal [2022 (5) TMI 240 - SUPREME COURT] and the Order of this Court[2022 (1) TMI 1291 - ORISSA HIGH COURT] and batch of writ petitions in M/s. Ambika Iron and Steel Pvt. Ltd. and others v. Principal Commissioner of Income Tax and others, the impugned notice is hereby quashed and all the subsequent orders and proceedings are also hereby quashed.
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