TMI Blog2023 (1) TMI 775X X X X Extracts X X X X X X X X Extracts X X X X ..... n and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, the same stood extended further. Petitioner in rejoinder, says that by virtue of Finance Act, 2021, the maximum timeframe under Section 149 of the Act has been reduced to ten years. This is a matter which would require examination qua both issues raised before us.Accordingly, issue notice. List the matter on 26.07.2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ction 148A(d) of the Income Tax Act, 1961 [in short Act ], and the consequent notice of even date i.e., 30.07.2022 passed under Section 148 of the Act, are flawed, for the reason that they are founded on an earlier notice dated 30.06.2021, which was addressed to the deceased/assessee i.e., Sh. Ladli Pershad Jaiswal. 2.1 In support of her submission, Ms Jha relies upon the judgment of this Cour ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... We are also informed, that a review petition was filed qua the judgment rendered by this Court, which was dismissed on 26.07.2019. [Review Petition No. 95/2019]. 5. Mr Sunil K. Aggarwal, who appears on behalf of the respondents/revenue, says that the explanation inserted by Finance Act, 2021 imbues Section 149 with retrospectivity. 5.1 In sum, it is Mr Aggarwal s contention, that the timefra ..... X X X X Extracts X X X X X X X X Extracts X X X X
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