2025 (1) TMI 1528

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ument is that for assessment year 2015-16 the limitation expired on 31.03.2022 whereas the notice under Section 148 of the Act was issued on 28.07.2022 - HELD THAT:- The notice for the assessment year 2015-16 was time-barred as the limitation expired on 31.03.2022, yet the notice was issued on 28.07.2022. This argument was supported by the Supreme Court's decision in Rajeev Bansal [2024 (10) T .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... t. The issue as to whether after Finance Act, 2021, the notice could have been issued under unamended Section 148 of the Act without following the procedure laid down under Section 148A of the Act was subject matter of challenge before the Supreme Court in the case of Union of India & Ors. Vs. Ashish Agarwal reported in 2023 (1)SCC 617. It was directed that notices issued under Section 148 of the .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ment is that for assessment year 2015-16 the limitation expired on 31.03.2022 whereas the notice under Section 148 of the Act was issued on 28.07.2022. 4. Learned counsel for the respondents submits that there are other issues raised in this petition but is not in a position to distinguish the present case from the case of Rajeev Bansal (supra). 5. The contention that there are other issues rais .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X