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2023 (9) TMI 1484 - HC - Income TaxIssues involved: Assessment Year 2012-13, Time-barred notice u/s 148 of the Income Tax Act, 1961. Assessment Year 2012-13: - The scrutiny assessment order u/s 143(3) was passed on 16.03.2015. - A search action u/s 132 was conducted on 01.09.2021. - The petitioner received a notice dated 13.03.2023, u/s 148, which is contended to be time-barred. - The petitioner's counsel referred to the proviso in Section 149(1) of the Act, along with Section 153A(1)(b) and Explanation 1. - The judgment of the Madurai Bench of the Madras High Court in a related case was cited. - The issue is also under consideration in another case before the same Court. - The respondent's counsel accepted the notice. - Counter-affidavit to be filed within two weeks, with a rejoinder if any, before the next hearing. - The matter is listed for 17.10.2023. - Stay on the notice dated 13.03.2023, until further court directions. - Parties to act based on the digitally signed copy of the order.
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