TMI Blog2022 (5) TMI 1550X X X X Extracts X X X X X X X X Extracts X X X X ..... Finance Act 2021, which introduced the new amended provisions i.e., Sections 147 to 151 with effect from 1st April, 2021 - HELD THAT:- Supreme Court of India in Union of India others v. Ashish Agarwal [ 2022 (5) TMI 240 - SUPREME COURT] partly allowed the appeals of the Union of India and made a distinction between notices issued by the Department on or after 1st April, 2021 and those that have ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .(C) No.12559 of 2022 - - - Dated:- 17-5-2022 - The Chief Justice And Justice R.K. Pattanaik For the Petitioner : Ms. K.R. Choudhury, Advocate For the Opposite Parties : Mr. R. Chimnaka, Senior Standing Counsel ORDER 01. 1. This matter is taken up by a separate notice. 2. The Court has been shown the Judgment dated 4th May 2022, passed by the Supreme Court of India in Civil ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eto. As regards the notices issued after 1st April 2021, the Supreme Court has in its operative portion held as under: 11. The present order shall be applicable PAN INDIA and all judgments and orders passed by different High Courts on the issue and under which similar notices which were issued after 01.04.2021 issued under section 148 of the Act are set aside and shall be governed by the pre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the respective judgments and orders passed by the various High Courts particulars of which are mentioned hereinabove, shall stand modified/ substituted to the aforesaid extent only. 5. In the present case, the notice under Section 148 of the Act pertaining to the Assessment Year (AY) 2015-16 was issued on 30th March 2021, i.e., prior to 1st April 2021. Also, it was beyond the period of six y ..... X X X X Extracts X X X X X X X X Extracts X X X X
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