TMI Blog2022 (11) TMI 1441X X X X Extracts X X X X X X X X Extracts X X X X ..... d the limitation period of six years stipulated in erstwhile Section 149 and the additional timeline prescribed under The Taxation and Other Laws Act, 2020 i.e., till 31st March, 2021 - HELD THAT:- As revenue states that as the impugned order has been passed without considering the reply dated 1st June, 2022, he has no objection if the impugned order u/s 148A(d) and notice u/s 148 both dated 18th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the petitioner. - Hon'ble Mr. Justice Manmohan And Hon'ble Ms. Justice Manmeet Pritam Singh Arora For the Petitioner : Mr. Ajay Kumar, Advocate with Mr. Prakash Kr. Sinha, Mr. Abhinav Dixit and Mr. Nirmal Kishore, Advocates. For the Respondents : Mr. Puneet Rai, Sr. Standing Counsel with Ms. Adeeba Mujahid, Jr. Standing Counsel and Mr. Nikhil Jain, Advocate. ORDER ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 149 of the Act and the additional timeline prescribed under The Taxation and Other Laws Act, 2020 i.e., till 31st March, 2021. Consequently, according to him, the impugned notice is barred by limitation by virtue of proviso to Section 149 of the Act. 4. Issue notice. 5. Mr. Puneet Rai, learned senior standing counsel for the respondent-revenue, accepts notice. He states that as the impugned ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Act and notice under Section 148 of the Act both dated 18th July, 2022 for the assessment year 2013-14 are set aside and the matter is remanded back to the Assessing Officer for a fresh decision. The Assessing Officer is directed to consider the replies dated 1st June, 2022 and 2nd June, 2022 filed by the petitioner and attached as Annexures P-12 P-13 to the present writ petition before passin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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