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TMI Blog2024 (12) TMI 1540X X X X Extracts X X X X X X X X Extracts X X X X ..... oor, Mr. Tarun Chanana and Ms. Ananya Kapoor, Advocates. For the Respondent : Mr. Gaurav Gupta, SSC alongwith Mr. Shivendra Singh and Mr. Yojit Pareek, JSCs for IT Department Revenue. ORDER 1. The petitioner has filed the present petition, inter alia, praying as under: "A. Issue a writ in the nature of Certiorari to quash the impugned notice dated 22.06.2021 issued under section 148 of the Ac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n'ble Court may deem fit and proper in the facts and circumstances of the case; and E. To allow the writ petition with cost in favor of the Petitioner and against the Respondent." 2. Learned counsel for the Revenue fairly states that the prayers made by the petitioner are required to be allowed as the same are covered by the concession made by the Revenue before the Supreme Court in Union of In ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation and Amendment of Certain Provisions) Act, 2020, Section 3 of the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 applies to the entire Income-tax Act, including sections 149 and 151 of the new regime. Once the first proviso to section 149(1)(b) is read with Taxation and other Laws (Relxation and Amendment of Certain Provisions) Act, 2020, then all the notic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t year 2015-2016, all notices issued on or after April 1, 2021 will have to be dropped as they will not fall for completion during the period prescribed under the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020." 4. In view of the aforesaid, the impugned order dated 19.07.2022 issued under Section 148(A)(d) of the Income Tax Act, 1961 (hereafter the Act) as well ..... X X X X Extracts X X X X X X X X Extracts X X X X
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