TMI Blog2022 (5) TMI 1614X X X X Extracts X X X X X X X X Extracts X X X X ..... .04.2021. Thus, it has been admitted by the respondents that the impugned notice under Section 148 of the Income Tax Act, 1961 was issued to the petitioner on 01.04.2021 i.e. after expiry of limitation on 31.03.2021. Respondents admits that the controversy involved in the present writ petition is covered by the judgment of Daujee Abhushan Bhandar Pvt. Ltd. Vs. Union Of India And 2 Others ( 2022 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , 1961 issued by the Respondent no.1 against the Petitioner under Section 148 of Income Tax Act, 1961 for Assessment year 2016-17 (Annexure 7 to the writ petition). b) Issue an appropriate writ, order or direction in the nature of Certiorari quashing the impugned assessment order and the demand notice under Section 147 read with Section 144B of the Income Tax Act 12/03/2022 passed by Responde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and Shri Manu Ghildyal, learned Standing Counsel for the respondent- Income Tax Department. This writ petition has been filed praying to quash the impugned notice dated 31.3.2021 issued on 1.4.2021 by the respondent no. 1 under Section 148 of the Income Tax Act, 1961, for the assessment year 2016-17 and the reassessment order dated 27.3.2022 passed by the respondent no. 2. Learned couns ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e aforequoted order, Sri Manu Ghildiyal, learned counsel for the respondent - Income Tax Department has produced the instructions of the concerned authorities of the Income Tax Department dated 04.05.2022. In the aforesaid instructions it is admitted that the impugned notice through email was sent to the petitioner on 01.04.2021. Thus, it has been admitted by the respondents that the impugned n ..... X X X X Extracts X X X X X X X X Extracts X X X X
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