Sudesh Teneja v. ITO

442 ITR 289High Court2022#16294 most cited
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LOVELY PROMOTERS PRIVATE LIMITED,KOLKATA vs. ACIT, CENTRAL CIRCLE, AJMER, AJMER

In the result, the appeal filed by the assessee is allowed

ITA 770/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Feb 2024AY 2013-14

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

For Appellant: Shri Mayank Taparia (Adv.)For Respondent: Shri A.S. Nehra (Addl.CIT) a
Section 127Section 127(1)Section 132Section 147Section 148Section 148ASection 151Section 153C

…y held that Time limit for issuing notice u/s 148 extended till 30-06-2021 is not applicable to AY 2013-14. We may also place reliance upon the decision of the the Hon’ble Rajasthan High Court Judgment in Sudesh Taneja v. 2022 TaxPub(DT) 805 (Raj-HC) : (2022) 442 ITR 289 (Raj) holding that new time limits as per substituted section 149(1)(b) not to apply to notices time barred under old provisions The time limits for issuing notice for reassessment have been changed. The concept of income chargeable to tax escaping assessment on account of failure on the part of the assessee to disclose truly or fully all materia…