TMI Blog2021 (12) TMI 1411X X X X Extracts X X X X X X X X Extracts X X X X ..... AL 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 27.04.2021, which extend, for the purpose of issuance of Notice under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ioned 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 been set to issue the notice under section 148 which is extended by N ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erved 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 learned senior advocate, Mr.Manish Bhatt and learned Additional Solicitor Genera ..... X X X X Extracts X X X X X X X X Extracts X X X X
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