JSVM Plywood Industries Ltd. v. ACIT (2022) 209 DTR 166 / 324 CTR 228 (Gau.)(HC)

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Validity of notice-section 148A would not apply till limitation prescribed under section 148 does not lapse or expire-Notice has stayed-Matter was adjourned to 24-1-2022. [S. 132, 148, 151, Art, 226]

 

Held that the notifications dt.27.02.2021 and 31.03.2021 issued by the CBDT, though extend the period of limitation in respect of issuance of notice u/s. 148 but the said notification is not empowered the CBDT to put into oblivion the provision of s. 148A of the Income Tax Act, which was inserted by virtue of the Finance Act, 2021 and was notified w.e.f. 01.04.2021, as if the said section 148A would not apply till the limitation prescribed under section 148 does not lapse or expire. Notice stayed and the matter was fixed for hearing on 24-1-2022 (WP)(C) / 6273 / 2021 dt.. 8-12 2021)