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2024 (7) TMI 581

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..... new amended provisions i.e., Sections 147 to 151 with effect from 1st April, 2021 - HELD THAT:- As decided in Bhagirathi Barik [ 2024 (4) TMI 1143 - ORISSA HIGH COURT] as also the decision in the case of Nutan Bhusan Jena [ 2022 (5) TMI 1467 - ORISSA HIGH COURT] wherein, the Hon ble Jurisdictional High Court of Orissa had following the decision of Hon ble Supreme Court in the case of Union of Ind .....

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..... at the notice u/s 148 of the Act came to be issued on 27.3.2021. It was the submission that notice u/s. 148 was time barred. For this proposition, ld AR has placed before us, the copies of the orders of Hon ble Jurisdictional High Court in the case of Bhagirathi Barik vs. Pr. CIT, Bhubaneswar in W.P.(C) No.7504 of 2024 order dated 3.4.2024 as also the decision in the case of Nutan Bhusan Jena vs P .....

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..... C) No.11181 of 2022 (Nutan Bhusan Jena vs The pr. CIT, Bhubaneswar-1 4. Considering that, the assessment year is 2013-14 and the impugned notice under section 148 of the Income tax Act, 1961 was issued on 28th March, 2021 for the reasons stated in the aforementioned order in Nutan Bhusana Jena (supra) as well as an earlier order of this Court dated 24th January, 2022 in W.P.(C) No.20919 of 2021 an .....

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..... ssions. As it is noticed that the issue in the present case is squarely covered by the decisions of the Hon ble Jurisdictional High Court of Orissa in the above mentioned cases, respectfully following the said decisions of Hon ble Jurisdictional High Court, it is held that the notice issued u/s. 148 is time barred and consequential proceedings and orders stand quashed. 7. In the result, appeal of .....

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