2025 (2) TMI 985

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..... or, Advocate For the Respondent : Mr Siddharth Sinha, SSC with Ms Dacchita Shahi, Advocate ORDER 1. The petitioner has filed the present petition, inter alia, impugning a notice dated 30.08.2024 (hereafter the impugned notice) issued under Section 148 of the Income Tax Act, 1961 (hereafter the Act) for the assessment year (AY) 2016-17. 2. The petitioner also impugns the notice issued under Sec .....

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..... e 1 April 2021; (ii) if it is barred at the time when the notice is sought to be issued because of the "time limits specified under the provisions of" 149(1)(b) of the old regime. Thus, a notice could be issued under Section 148 of the new regime for assessment year 2021-2022 and before only if the time limit for issuance of such notice continued to exist under Section 149(1)(b) of the old regime. .....

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..... ad the power to reopen assessments for the year 2012-2013 if the escaped assessment amounted to Rupees fifty lakhs or more. The proviso limits the retrospective operation of Section 149(1)(b) to protect the interests of the assesses." 5. In the present case, the period of six years for the relevant AY 2016-17, thus, expired on 31.03.2022. The impugned notice has been issued thereafter, and the sa .....

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