9911796707
TMI Blog2023 (5) TMI 366X X X X Extracts X X X X X X X X Extracts X X X X ..... A HIGH COURT] was a lead matter, declined to interfere relegating the parties to a stage of passing of assessment orders under Section 148 of the Act. In doing so, this Court followed the order of the Supreme Court of India Anshul Jain v. Principal Commissioner of Income Tax [ 2022 (10) TMI 3 - SC ORDER] which in turn affirmed the judgment of Anshul Jain v. Principal Commissioner of Income Tax) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arance filed by Mr. Sidharth Sankar Mohapatra, learned Senior Standing Counsel for Income Tax Department-Opposite Parties is taken on record. 2. As regards the challenge to an order passed under Section 148A(d) of the Income Tax Act, 1961 (Act) at an intermediate stage, this Court has in its order dated 1st December, 2022 in a batch of writ petitions of which W.P.(C) No.9191 of 2022 ( Kailash K ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ere another order dated 2nd June, 2022 of the High Court of Punjab and Haryana in CWP No.10073 of 2022 ( Red Chilli International Sales v. Income Tax Officer ) was challenged. In the said SLP (C) No.86 of 2023, the following order was passed by the Supreme Court of India on 3rd January, 2023: Delay condoned. We with the petitioner that the impugned judgment rejecting the writ petition on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hen it arise for consideration. We do deem it open to examine this issue in the present case after having examined the notice under Section 148A (b) including the annexure thereto, the reply filed by the petitioner and the order under Section 148A (d) of the Income Tax Act, 1961. Recording the aforesaid, the special leave petition is disposed of. We clarify that the dismissal of the special l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ct was time barred, it is also vitiated by what he terms as mere change of opinion by the Assessing Officer. 7. Needless to say, it will be open to the Petitioner to raise all grounds available to the Petitioner in accordance with law, including the above grounds at the appropriate stage as explained by this Court in its order in Kailash Kedia (supra) . 8. The petition is accordingly disp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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