Allowing the petition the Court held that in view of the judgments in Union of India v. Ashish Agarwal (supra) and Ambika Iron and Steel Pvt. Ltd. v. PCIT (2023) 452 ITR 285 (Orissa)(HC)) the notice under section 148 which was issued on March 30, 2021, i. e., prior to April 1, 2021 beyond the period of six years from the A.Y. 2015-16 against the assessee was quashed. Consequently, all the subsequent orders and proceedings were also quashed. (AY 2015-16)
Salu Agarwal v. ITO (2023) 453 ITR 784 (Orissa)(HC) Editorial: SLP of revenue dismissed, ITO v. Salu Agarwal (2023) 433 ITR 786 (SC)
S. 147 : Reassessment -Notice after six years-Sanction-Notice dated 30-3-2021 issued under old provision after coming into effect of new provision from 1-4-2021 -UOI v. v. Ashish Agarwal(2022) 444 ITR 1 (SC) – Notice and subsequent orders and proceedings are quashed. [S. 148, 151, Art,226]