9911796707
TMI Blog2025 (4) TMI 330X X X X Extracts X X X X X X X X Extracts X X X X ..... or, Advocate. For the Respondent : Mr Vipul Aggarwal, SSC. ORDER 1. The petitioner has filed the present petition, inter alia, impugning a notice dated 31.08.2024 (hereafter the impugned notice) issued under Section 148 of the Income Tax Act, 1961 (hereafter the Act) for the assessment year (AY) 2014-15. 2. The petitioner also impugns the notice issued under Section 148A(b) of the Act, and th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the time when the notice is sought to be issued because of the "time limits specified under the provisions of" 149(1)(b) of the old regime. Thus, a notice could be issued under Section 148 of the new regime for assessment year 2021-2022 and before only if the time limit for issuance of such notice continued to exist under Section 149(1)(b) of the old regime. *** *** *** 49. The first provis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or the year 2012-2013 if the escaped assessment amounted to Rupees fifty lakhs or more. The proviso limits the retrospective operation of Section 149(1)(b) to protect the interests of the assesses." 5. In the present case, the period of six years from the end of the relevant AY 2014-15 expired on 31.03.2021. The impugned notice has been issued thereafter, and the same is thus barred by limitation ..... X X X X Extracts X X X X X X X X Extracts X X X X
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