TMI Blog2021 (12) TMI 1411X X X X Extracts X X X X X X X X Extracts X X X X ..... the provision of section 147 with effect from 01.04.2021 and the time limit has been set to issue the notice under section 148 which is extended by Notification No.20 of 2021 and 38 of 2021, there cannot be two parallel provisions applicable simultaneously - validity of Notification No.20 of 21 issued by the CBDT by purportedly exercising the powers conferred by section 3 (1) of the Taxation and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... For The Petitioner(s) No. 1 MR SN DIVATIA(1378) ORAL ORDER (PER : HONOURABLE MS. JUSTICE SONIA GOKANI) 1. The petitioner has preferred this petition before this Court under Article 226 of the Constitution of India challenging the constitutional validity and vires of the Explanation contained in Notification No.20/2021 dated 31.03.2021 as well as Notification No.38/2021 dated 27. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the aforesaid notifications. 2. The petitioner has further questioned the applicability of the provisions of sections 148 and 148 A of the Income Tax Act, the new provisions which have been inserted by Finance Act 2021 with effect from 01.04.2021. 3. According to the petitioner, the Financial Act has substituted the provision of section 147 with effect from 01.04.2021 and the time limit has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be completed and office of learned Additional Solicitor General shall be served through e-mail as well as speed post. 6. As the petitioner has made out a prima facie case, ad-interim order in terms of paragraph 10(f) till the returnable date. 7. Direct service is permitted. Service be effected directly by the petitioner through speed post. Soft copy shall be served upon the offices of the le ..... X X X X Extracts X X X X X X X X Extracts X X X X
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