S. 148 : Reassessment-Notice-Notice for assessment year 2013-14 was issued to assessee on 1-4-2021-limitation of issuing notice expired on 31-3-2021-Notice was time barred-Direction-CBDT-Since large number of writ petitions are being filed in which date and time of issuance of notice under section 148 are in dispute, Income-tax department to be directed to ensure that date and time of triggering of e-mail for issuing notices and orders are reflected in online portal relating to concerned assesses-Unless there is a stay obtained by authorities under Income-tax Act, 1961 from higher forum, mere fact of filing appeal or SLP will not entitle authority not to comply with order of High Court-Court directed the Registrar General to forward the copy of the judgement for circulating amongst authorities under the Income tax- Act , 19961 and for the observance of the principles of the judicial discipline and propriety. [S. 147, 260A, Art. 226]
Mohan Lal Santwani v. UOI (2022) 449 ITR 476/ 287 Taxman 634 / 218 DTR 313 / 329 CTR 113(All.)(HC)