9911796707
TMI Blog2022 (4) TMI 1323X X X X Extracts X X X X X X X X Extracts X X X X ..... ed time limit specified in Section 149 - initiation of reassessment proceedings prior to coming into force of the Finance Act, 2021 - substitution made by the Finance Act, 2021 - legality and validity of only the Explanations to the two Notifications, being Notification No.20/2021 dated 31st March, 2021 and Notification No.38/2021 dated 27th April, 2021, issued by Central Government in exercise of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s declared Explanations A(a)(ii)/A(b) in the Notification No. 20/2021 dated 31.03.2021 and Notification No. 38/2021 dated 27.04.2021 as ultra vires, the relief sought by the Petitioner herein, in prayer (b) stands redressed and no further orders are required to be passed. X X X X Extracts X X X X X X X X Extracts X X X X ..... ons No. 20/2021 dated 31.03.2021 (ANNEXURE-2) and 38/2021 dated 27.04.2021 (ANNEXURE-3) issued by Respondent No.3 (CBDT) which are ultra vires to the TOL Act." 2. We have heard learned counsels appearing on behalf of the parties and have looked into the facts and circumstances of the case. 3. Learned counsel for the Petitioner, at the outset, submits that the issue raised in the present writ pet ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Notification No. 20/2021 dated 31.03.2021 and Notification No. 38/2021 dated 27.04.2021 as ultra vires, the relief sought by the Petitioner herein, in prayer (b) stands redressed and no further orders are required to be passed. 7. Needless to state, if the law permits the Respondents/Revenue to take further steps in the matter, they shall be at liberty to do so and, if and when such steps ar ..... X X X X Extracts X X X X X X X X Extracts X X X X
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