2022 (12) TMI 1424

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..... Rai, Sr. Standing Counsel with Ms Adeeba, Jr. Standing Counsel. ORDER W.P.(C) 12220/2022 & CM Appl. 36635/2022 [Application filed on behalf of the petitioner seeking interim relief] 1. The substantive prayer made in the writ petition reads as follows: "a. Issue an appropriate Writ, direction or order quashing and setting aside the Order passed u/s 148A(d) and notice u/s 148 of the Income .....

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..... oceedings were therefore time barred as the window available to the respondent/revenue for issuance of fresh notices under the new regime was available only between 01.04.2021 and 30.06.2021. 5. Since in this case the notice was dispatched only on 14.07.2021, the proceedings are time barred. 5.1. In support of his plea, Mr Agarwal relies upon the judgment of a coordinate bench of this Court date .....

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..... ect is concerned, Mr Rai says that there is no specific assertion in the counter-affidavit. Therefore, quite clearly, the department has not taken a stand either way, on the assertion made that the said amount has been taxed in the hands of the creditor. 8. Thus, for the foregoing reasons we are inclined to set aside the impugned order passed under Section 148A(d) and notice issued under Section .....

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