TMI Blog2024 (7) TMI 581X X X X Extracts X X X X X X X X Extracts X X X X ..... C. Mohanty, Sr DR ORDER PER BENCH This is an appeal filed by the assessee against the order of the ld CIT(A), NFAC, Delhi dated 13.2.2024 in Appeal No.NFAC/2012-13-10125929 for the assessment year 2013-14. 2. Shri Sunil Mishra and Shesadada Das, ld ARs appeared for the assessee and Shri S.C.Mohanty, Ld Sr DR appeared for the revenue. 3. It was submitted by ld AR that the assessment year invol ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion 3(1) of the taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and the fact that the petitioner has an alternative remedy of assailing the order of the assessment and order of the appellate authority. 3. As regards the first issue, the judgment of the Supreme Court in Union of India vs. Ashish Agarwal, 444 ITR 1(SC) is a complete answer. This has been taken n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he case of Poonam Agrrawal vs ITO in W.P.(C)No.22678 of 2022, wherein, the Hon'ble Jurisdictional High Court has quashed the notice issued u/s. 148 of the Act and consequential proceedings and orders holding the same as being time barred. 5. In reply, ld Sr DR vehemently supported the order of the Assessing Officer and ld CIT(A). It was the submission that the period of extention on account COVID ..... X X X X Extracts X X X X X X X X Extracts X X X X
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