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TMI Blog2025 (5) TMI 365X X X X Extracts X X X X X X X X Extracts X X X X ..... eep Singh Rawat, Mr. Girish Chandra & Mr. Pankaj Pandey, Advocates. For the Respondents Through: Mr. Shlok Chandra, Sr. Standing Counsel with Ms. Naincy Jain, Jr. SC, Ms. Madhavi Shukla, Jr. SC & Mr. Ujjwal Jain, Advocate. VIBHU BAKHRU, J. (Oral) 1. The Petitioner [Assessee] has filed the present petition, inter alia, impugning a notice dated 11.07.2022 [the impugned notice] issued under Sect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under Section 148A (b) of the Act and further granted time to the Assessing Officer [AO] to supply the information and material on which such notices were premised. 3. In compliance with the directions issued by the Supreme Court in the case of Union of India & Others. v. Ashish Agarwal (supra), the AO provided information and material to the Assessee on 26.05.2022. The Assessee was granted two ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Act was issued on 23.06.2021, which was seven days before the expiry of the extended period of limitation. 6. As noted above, the said notice was deemed to be a notice under Section 148A (b) of the Act by virtue of the decision of the Supreme Court in Union of India & Ors. v. Ashish Agarwal (supra). The Supreme Court also granted further time to provide the material required to accompany such ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... period expired on 18.06.2022. However, the impugned notice was issued on 11.07.2022, which is beyond the prescribed period. Therefore, the notice issued was beyond the period of limitation. 8. Concededly, the said controversy is covered in favour of the Assessee by the decision of this court in Ram Balram Buildhome Pvt. Ltd. v. Income Tax Officer and Anr.: Neutral Citation: 2025:DHC:547-DB. 9. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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