TMI Blog2022 (4) TMI 1644X X X X Extracts X X X X X X X X Extracts X X X X ..... proceedings u/s 147 of the Act under which issuance of notice u/s 148A is mandatory before issuing any notice under section 148 of the amended Act which has not been complied with in this case. Considering the above facts and circumstances of the case and in view of the order of this Court in the case of Bagaria Properties and Investment Private Limited Anr. v. Union of India ORs [ 2022 (1) TMI 7 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by limitation and that the respondent-income tax authority concerned, before issuing the impugned notices under section 148 of the 1961 Act, has not observed the statutory formalities under section 148A of the 1961 Act as prescribed by the Finance Act, 2021 which are applicable with effect from 1st April, 2021 before issuance of notices under section 148 of the 1961 Act on or after 1st April, 202 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ice under section 148 of the amended Act which has not been complied with in this case. 6. Considering the above facts and circumstances of the case and in view of the order of this Court in the case of Bagaria Properties and Investment Private Limited Anr. v. Union of India Ors. reported in (2022) 134 taxman.com 196 (Calcutta) and also in the case of Monoj Jain v. Union of India reported in (2022 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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