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2022 (11) TMI 1443 - HC - Income TaxReopening of assessment u/s 148 - Period of limitation - review application has been filed praying for review of the judgment and order dated [2022 (5) TMI 1614 - ALLAHABAD HIGH COURT] on the ground that the Assessing Officer has also put signature on the notice under Section 148 of the Income Tax Act, 1961 - HELD THAT:- We have perused our judgment and order above we find that it was passed after affording opportunity of hearing to the applicants, i.e. the Department. Departmental counsel argued the matter after obtaining instructions dated 04.05.2022 from the concerned authority. We have also noted in our aforesaid judgment and order dated 06.05.2022 that in the aforesaid instructions it is admitted that the impugned notice through e-mail was sent to the petitioner on 01.04.2021. Thus, it was admitted by the respondents that the impugned notice under Section 148 of the Income Tax Act, 1961 was issued to the petitioner on 01.04.2021 i.e. after expiry of limitation on 31.03.2021. In view of the aforesaid, we do not find any manifest error in our judgment dated 06.05.2022. We find no merit in this review application.
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