9911796707
TMI Blog2025 (4) TMI 46X X X X Extracts X X X X X X X X Extracts X X X X ..... praying as under: - "A. Issue a writ of and/or order and or directions in the nature of certiorari or any other appropriate writ, order or direction quashing the notice dated 19.05.2022 issued under Section 148A (b) of the Act; impugned notice dated 27.07.2022 issued under Section 148 of the Act and the impugned order dated 27.07.2022 passed under Section 148A (d) of the Act by the Respondent No. 1 and the proceedings initiated pursuant thereto; B. Issue a writ of and/or order and/or direction in the nature of Prohibition commanding Respondents to forebear from giving effect to and/or taking any step whatsoever pursuant to and/or in furtherance of the said purported notice under Section 148 of the Act and/or in any proceedings initiate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... le, several petitions were filed assailing such notices that were issued under Section 148 of the Act after 31.03.2021 but following the statutory regime for reassessment as was in enforce prior to the said date. Some of these petitions were allowed on 15.12.2021 by a decision in Mon Mohan Kohli v. ACIT & Anr.: Neutral Citation No.: 2021:DHC:4181-DB and other connected matters. Similar decisions were rendered by some other High Courts. 7. These decisions were appealed by the Revenue before the Supreme Court. In Union of India & Others v. Ashish Agarwal: (2023) 1 SCC 617, the Supreme Court, issued certain directions in exercise of powers its under Article 142 of the Constitution of India including the direction to treat such notices issued ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y of Limitation read with TOLA for (4) (5) 2013-2014 31.03.2017 TOLA not applicable 31.03.2020 30.06.2021 2014-2015 31.03.2018 TOLA not applicable 31.03.2021 30.06.2021 2015-2016 31.03.2019 TOLA not applicable 31.03.2022 TOLA not applicable 2016-2017 31.03.2020 30.06.2021 31.03.2023 TOLA not applicable 2017-2018 31.03.2021 30.06.2021 31.03.2024 TOLA not applicable (f) The Revenue concedes that for the assessment year 2015-2016, all notices issued on or after 1 April 2021 will have to be dropped as they will not fall for completion during the period prescribed under the TOLA." 9. Following the aforesaid concession, this court in Ibibo Group Private Limited v Assistant Commissioner of Income Tax Circle 10-1, & Anr. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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