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TMI Blog2021 (9) TMI 1481X X X X Extracts X X X X X X X X Extracts X X X X ..... the time limit specified in Section 149 or sanction u/s 151 of the Act from 31.03.2021 to 30.04.2021 and from 30.04.2021 to 30.06.2021 respectively - HELD THAT:- According to the petitioner, the Financial Act has substituted the provision of section 147 with effect from 01.04.2021 and the time limit has been set to issue the notice under section 148 which is extended by Notification No.20 of 2021 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e of learned Additional Solicitor General shall be served through e-mail. - R/SPECIAL CIVIL APPLICATION NO. 13433 of 2021 - - - Dated:- 17-9-2021 - HONOURABLE MS. JUSTICE SONIA GOKANI AND HONOURABLE MR. JUSTICE RAJENDRA M. SAREEN LD. SR.ADV. SHRI TUSHAR P. HEMANI WITH MS VAIBHAVI K PARIKH AND MR.PARIMAL SINH B. PARMAR ADVOCATES (3238) for the Petitioner No. 1 ORAL ORDER (PER : ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aken during this extended time limit. The petitioner also challenges the consequential notice dated 21.04.2021 issued under Section 148 of the Act as existed and applicable as on 31.03.2021 seeking to reopen the Income Tax Assessment of the petitioner for the assessment year 2014-2015 by drawing power and authority from the aforesaid notifications. 2. The petitioner has further questioned the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... i Tushar P. Hemani with learned advocates, Ms.Vaibhavi Parikh and Mr.Parimalsinh Parmar for the petitioner. It is urged fervently that even the Revenue Authorities could not have extended the operation of repealed provision of section 148 beyond 31.03.2021 under the guise of a clarificatory explanation in the notifications. 5. Issue NOTICE to the respondents returnable on 05.10.2021. Pleadings ..... X X X X Extracts X X X X X X X X Extracts X X X X
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