TMI Blog2023 (2) TMI 1171X X X X Extracts X X X X X X X X Extracts X X X X ..... the notice is dated 30.06.2021, the e-mail that has been placed on record evidencing service of the impugned notice, bears a date and time stamp: 16.07.2021 at 12:12 A.M. No other document establishing delivery of the impugned notice on any date prior to 16.07.2021 has been placed on record by the respondent/revenue. In these circumstances, we agree with learned Counsel for the petitioner/asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the petitioner on 16.07.2021, on the ground that it is not in accordance with the new regime introduced by the Finance Act, 2021, being barred by limitation and hence, illegal and invalid in the eyes of law. The impugned notice relates to Assessment Year (AY) 2013-14. 2. Based on the impugned notice, an order dated 29.06.2022 under Section 148A(d) of the Act was passed against the petitione ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al 2022 SCC OnLine SC 543 , does not apply to the case of the petitioner, since only notices under the erstwhile provisions of Section 148 of the Act issued between 01.04.2021 to 30.06.2021 are deemed to have been issued under the new Section 148A of the Act. 4. Mr Abhishek Maratha, learned Senior Standing Counsel, who appears on behalf of the respondent/revenue submits that the impugned notic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... epted by the respondent/revenue that even though the notice is dated 30.06.2021, the e-mail that has been placed on record evidencing service of the impugned notice, bears a date and time stamp: 16.07.2021 at 12:12 A.M. No other document establishing delivery of the impugned notice on any date prior to 16.07.2021 has been placed on record by the respondent/revenue. 6. In these circumstances, we ..... X X X X Extracts X X X X X X X X Extracts X X X X
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