2022 (7) TMI 64

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..... tion - scope of statutory formalities under section 148A as prescribed by the Finance Act, 2021 which are applicable with effect from 1st April 2021 before issuance of notices under section 148 of the 1961 Act on or after 1st April 2021 - HELD THAT:- In considered view that this case clearly falls under the amended Act relating to proceedings under section 147 of the Act under which issuance of no .....

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..... n, J. Mr. Avra Mazumder Sk. Md. Bilwal Hossain Mr. Binayak Gupta …for the petitioner Mr. Amit Sharma …for the respondents ORDER Heard learned advocates appearing for the respective parties. Petitioner in this writ petition is aggrieved by the issuance of impugned notice under section 148 of the Income Tax Act, 1961 on the grounds that the same is barred by limitation and tha .....

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..... uploaded for communication on April 1, 2021 at 3 a.m. which has to be treated as date of issuance of the impugned notice. Considering these facts, I am of the considered view that this case clearly falls under the amended Act relating to proceedings under section 147 of the Act under which issuance of notice under section 148A of the Act is mandatory before issuing any notice under section 148 of .....

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