9911796707
TMI Blog2022 (11) TMI 1483X X X X Extracts X X X X X X X X Extracts X X X X ..... ssment proceeding by relying on an instruction being No. 01/2022 dated 11th May, 2022 issued by CBDT. HELD THAT:- Admittedly, the issuance of notice and initiation of re-assessment proceeding are beyond six years and, prima facie, it is barred by limitation both under the old Act as well as under newly amended provision relating to Section 147 of the Act. This matter deserves adjudication by calli ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ords. 3. By this writ petition, petitioner has challenged the impugned order dated 27th July, 2022 under Section 148A(d) of the Income Tax Act, 1961 relating to assessment year 2014-15, and, all subsequent proceedings based on the impugned notice dated 30th June, 2021 under Section 148 of the Income Tax Act, 1961, mainly on the ground of jurisdiction of the assessing officer in issuance of the imp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to make out a prima facie case for an interim order by raising the issue of jurisdiction of the assessing officer concerned in initiating the impugned re-assessment proceeding. 5. Let the respondents file affidavit-in-opposition within four weeks; petitioner to file reply thereto, if any, within two weeks thereafter. 6. The matter shall appear for final hearing in the monthly list of February, 20 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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