9911796707
TMI Blog2024 (6) TMI 694X X X X Extracts X X X X X X X X Extracts X X X X ..... to issue the notice dated 26th April, 2023 u/s 148 of the Income Tax Act, 1961 as amended by Finance Act, 2021 - as argued no notice under Section 148 of the said Act can be issued in respect of the assessment year 2016-17, beginning on or before 1st April, 2021 in terms of the amended provisions of Section 149 of the said Act, since notice was issued for the assessment year 2016-17 and should fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ree weeks after the summer vacation. Reply thereto, if any, be filed within two weeks thereafter. List this matter in the Combined Monthly List of July, 2024. - Raja Basu Chowdhury, J. Mr. Vinay Shraff Mr. Dev Kumar Agarwal For the petitioner Mr. Tilak Mitra For the respondents ORDER 1. The present writ petition has been filed, inter alia, questioning the jurisdiction and/or authority of the jur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iately before the commencement of the Finance Act, 2021. 3. Independent of the above, by placing before this Court the notice dated 29th March, 2021, issued under Section 148 of the said Act, in respect of the assessment year 2016-17 it is submitted that since, reassessment proceeding had commenced pursuant to the aforesaid notice dated 29th March, 2021 and the same having already been concluded b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to use affidavit-in-opposition to the present writ petition. 5. Having regard to the aforesaid, considering the fact that no second notice under Section 148 of the said Act in respect of the assessment year 2016-17 could have been issued and further taking note of the amended provisions of Section 149 of the said Act, including the jurisdictional issue involved, I am of the view that the writ peti ..... X X X X Extracts X X X X X X X X Extracts X X X X
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