TMI Blog2022 (12) TMI 1423X X X X Extracts X X X X X X X X Extracts X X X X ..... in Provisions) Act, 2020 - HELD THAT:- The record shows that on two previous occasions, i.e., 10.10.2022 and 21.11.2022, opportunity was given to Mr Maratha to obtain instructions. Obviously, no instructions have been received by Mr Maratha. Issue notice. Respondents accepts notice on behalf of the respondents (which includes CBDT/respondent no.3). A counter-affidavit will be filed within three ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .1 Besides this, challenge is also laid to the notice/letter dated 13.05.2022 issued under Section 148A(b) of the Act and the order dated 27.07.2022 issued under Section 148A(d) of the Act. 2.2 In addition thereto, Instruction No.1 dated 11.05.2022 issued by the Central Board of Direct Taxes (CBDT)/respondent no.3 which, evidently, has been issued pursuant to the judgment of the Supreme Court r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee i.e., between 01.04.2021 and 30.06.2021 as per the provisions of Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 [in short, TOLA ]. 5. We may also note that Mr Jain has submitted before us that since the assessment year (AY) under consideration is 2014-2015 and there was a complete disclosure of the purported escaped income; limitation, in the normal c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aratha to obtain instructions. Obviously, no instructions have been received by Mr Maratha. 8. Issue notice. 8.1. Mr Abhishek Maratha accepts notice on behalf of the respondents (which includes CBDT/respondent no.3). 9. A counter-affidavit will be filed within three weeks from today. 9.1 Rejoinder thereto, if any, will be filed before the next date of hearing. 10. List the matter on ..... X X X X Extracts X X X X X X X X Extracts X X X X
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