Bhulakshmi House Building Co. Operative Society R v. Income Tax Officer

Karnataka HC18 Dec 2025WP/2496/2025

Case brief

AI extract

What is this about?

AY 2013-14 reassessment quashed as time-barred: deemed s.148A(b) notice after Ashish Agarwal; information supplied 24.05.2022; limitation expired 14.06.2022 ('surviving time', Rajeev Bansal 2024 INSC 754); s.148A(d) order and s.148 notice dated 27/28.07.2022 invalid; consequential intimation, s.147 r.w.s 144 assessment order and s.271 penalty orders quashed; Karnataka HC writ/certiorari under Articles 226-227; co-operative society assessee; TOLA-based limitation computation discussed.

What did the court decide?

Petition allowed; the impugned orders/notices at Annexures A, A1, A2, A3, A4, A5, A6, A7, A8, A9 and A10 dated 30.06.2021, 24.05.2022, 27.07.2022, 28.07.2022, 28.07.2022, 02.11.2022, 29.05.2023, 16.10.2023, 20.10.2023, 31.10.2023 and 15.11.2023 respectively were quashed. ¶124

Bhulakshmi House Building Co. Operative Society R Vs Income Tax… — Income Tax | Karnataka HC (2025)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the order under Section 148A(d) dated 27.07.2022 and the notice under Section 148 dated 28.07.2022 for AY 2013-14 were issued beyond the 'surviving time' and hence barred by limitation, as contended by the petitioner relying on the directions in Union of India v. Ashish Agarwal and the ruling in Union of India v. Rajeev Bansal. +1 more

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Court's answer

Since information and material pursuant to the Ashish Agarwal directions was furnished to the petitioner on 24.05.2022, the period of limitation for passing the order under Section 148A(d) and issuing the notice under Section 148 expired on 14.06.2022; consequently, the impugned order dated 27.07.2022 and the notice dated 28.07.2022 were hopelessly and clearly barred by limitation, as held in Rajeev Bansal.

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Ratio / Principle

Adopting a view similar to that taken by the Delhi High Court and other High Courts, the impugned order and notices at Annexures A, A1, A2, A3, A4, A5, A6, A7, A8, A9 and A10 deserve to be quashed.

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Detailed headnote1 paragraphs

Karnataka HC (S.R. Krishna Kumar J) allowed W.P. 2496/2025 (T-IT) of Bhulakshmi House Building Co-operative Society seeking certiorari against the AY 2013-14 reassessment chain. The 30.06.2021 notice under unamended s.148, deemed a s.148A(b) show-cause notice per Union of India v. Ashish Agarwal, led the Revenue to furnish information on 24.05.2022, fixing the limitation expiry at 14.06.2022. The s.148A(d) order dated 27.07.2022 and s.148 notice dated 28.07.2022, issued beyond that 'surviving time' as held in Union of India v. Rajeev Bansal (2024 INSC 754) and followed by the Gujarat High Court in Southern Gujarat Chamber, were time-barred. Accordingly all Annexures A-A10, including the intimation letters, the order under s.147 r.w.s 144 and the penalty orders under ss.271(1)(b), 271F, 2718 (sic) and 271(1)(c), were quashed.

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NC: 2025:KHC:54682 WP No. 2496 of 2025

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HC-KAR

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IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18^TH DAY OF DECEMBER, 2025

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BEFORE

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THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 2496 OF 2025 (T-IT)

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BETWEEN:

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BHULAKSHMI HOUSE BUILDING CO OPERATIVE SOCIETY R REGISTERED UNDER SECTION 8 OF KARNATAKA CO-OPERATIVE SOCIETIES ACT 1959, NO.362, 1^ST FLOOR, CHELUVAMBA AGRAHARA, K R MOHALL MYSORE-570024. PRESENTLY AT: 419, NEW KA12/1, INFRONT OF SEETHARAMA KALYANA MANTAPA, DEVAAMBHA AGRAHARA , K R MOHALLA MYSORE – 570 024 PAN AACT B12234 PRESENTLY HOLDING PAN AAEAB3952D REPRESENTED BY ROOPA B K SECRETARY OF THE PETITIONER, AGED 38 YEARS, NO.52, 1^ST STAGE, 2^ND CROSS GANGOTHRI LAYOUT MYSORE- 570 009.

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…PETITIONER

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Digitally signed by CHANDANA B M Location: High Court of Karnataka

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(BY SRI. RAVI SHANKAR.S.V, ADVOCATE) AND:

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INCOME TAX OFFICER WARD-1 (1), MYSORE- 570 008.

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NATIONAL FACELES ASSESMENT CENTRE, ADDITIONAL /JOINT/DEPUTY/ ASSISTANT COMMISIONER OF INCOME TAX/INCOME TAX OFFICER INCOME TAX DEPARTMENT MINISTRY OF FINANCE ROOM NO.401, 2^ND FLOOR E-RAMP, JAWAHARLALA NEHRU STADIUM

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DELHI-110 003.

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NC: 2025:KHC:54682 WP No. 2496 of 2025

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HC-KAR

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THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX C R BUILDING QUEEN ROAD, BANGALORE- 560 001.

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…RESPONDENTS

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(BY SRI. M. THIRUMALESH, ADVOCATE)

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THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUITON OF INDIA PRAYING TO QUASH THE NOTICE UNDER SECTION 148 OF THE DTD. 30.06.2021 BEARING DIN NO. ITBA/AST/S/148/2021-22/1033907418(1) ISSUED BY THE R-1 FOR THE ASSESSMENT YEAR 2013-14 HEREIN MARKED AS ANNX-A.

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THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

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CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR

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ORAL ORDER

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In this petition, petitioner seeks for the following reliefs:-

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“ i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148 of the Act, dated 30/06/2021 bearing DIN No. ITBA/AST/S/148/2021-22/1033907418(1), Issued by the Respondent No. 1 for the assessment year 2013-14 herein marked as Annexure - A.

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ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148A(b) of the Act, dated 24/05/2022 bearing DIN No. ITBA/COM/F/17/2022-23/1043131008(1), issued by the Respondent No.1 for the assessment year 2013-14 herein marked as Annexure - A1.

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iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order under Section

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HC-KAR

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148A(d) of the Act, dated 27/07/2022, bearing DIN No. ITBA/COM/F/17/2022-23/1044145958(1) issued by the Respondent No.1 for the assessment year 2013-14 herein marked as Annexure - A2.

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iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148 of the Act dated 28/07/2022 bearing DIN No. ITBA/COM/F/17/2022-23/1044240467(1) issued by the Respondent No.1 for the assessment year 2013-14 herein marked as Annexure - A3.

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v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the intimation letter dated 28/07/2022 for notice under Section 148 of the Act bearing DIN No. ITBA/AST/S/91/2022-23/1044243618(1), issued by the Respondent No.1 for the assessment year 2013-14 herein marked as Annexure A4.

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vi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the intimation of procedure under Section 1448 of the Act dated 02/11/2022 bearing DIN No. ITBA/AST/S/61/2022-23/1046750133(1), issued by the Respondent No.2 for the assessment year 2013-14 herein marked as Annexure - A5.

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vii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed Under section 147 r.w.s 144 dated 29/05/2023 bearing DIN No. ITBA/AST/S/147/2023-24/1053293306(1) Issued by the Respondent No.1 for the assessment year 2013-14 herein marked as Annexure A6.

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HC-KAR

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viii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order under Section 271(1)(b) of the Act dated 16/10/2023 bearing DIN No. ITBA/PNL/F/271(1)(b)/2023-24/1057101782(1), issued by the Respondent No.2 for the assessment year 2013-14 herein marked as Annexure- A7.

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ix) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order under section 271F of the Act dated 20/10/2023 bearing DIN No. ITBA/PNL/F/271F/2023-24/1057269217(1), issued by the Respondent No.2 for the assessment year 2013-14 herein marked as Annexure A8.

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x) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order under section 2718 of the Act dated 31/10/2023 bearing DIN No. ITBA/PNL/F/2718/2023-24/1057532807(1), Issued by the Respondent No.2 for the assessment year 2013-14 herein marked as Annexure A9.

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xi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order under section 271(1)(c) of the Act dated 15/11/2023 bearing DIN No.ITBA/PNL/F/271(1)(c)/2023-24/1057959548(1), issued by the Respondent No.2 for the assessment year 2013-14 herein marked as Annexure - A10.

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xii) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.”

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Heard learned counsel for the petitioner and learned

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counsel for the respondents and perused the material on record.

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HC-KAR

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A perusal of the material on record will indicate that in relation to the assessment year 2013-14, the respondent No.1 issued a notice dated 30.06.2021 under Section 148 of the Income Tax Act, prior to the said provisions being amended w.e.f., 01.04.2021. Subsequently, in the case of Union of India vs. Ashish Agarwal [2022] 138 taxmann.com 64 (SC), the Apex Court while dealing with the aforesaid amendment and notices issued to the assessee under Section 148 subsequent to the amendment, issued the following directions:

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"10. In view of the above and for the reasons stated above, the present Appeals are ALLOWED IN PART. The impugned common judgments and orders passed by the High Court of Judicature at Allahabad in W.T. No. 524/2021 and other allied tax appeals/petitions, is/are hereby modified and substituted as under:

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(i) The impugned section 148 notices issued to the respective assessees which were issued under unamended section 148 of the IT Act, which were the subject matter of writ petitions before the various respective High Courts shall be deemed to have been issued under section 148A of the IT Act as substituted by the Finance Act, 2021 and construed or treated to be show cause notices in terms of section 148A(b). The assessing officer shall, within thirty days from today provide to the respective assessees information and material relied upon by the Revenue, so that the assesees can reply to the show cause notices within two weeks thereafter;

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HC-KAR

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(ii) The requirement of conducting any enquiry, if required, with the prior approval of specified authority under section 148A(a) is hereby dispensed with as a onetime measure visàvis those notices which have been issued under section 148 of the unamended Act from 01.04.2021 till date, including those which have been quashed by the High Courts. Even otherwise as observed hereinabove holding any enquiry with the prior approval of specified authority is not mandatory but it is for the concerned Assessing Officers to hold any enquiry, if required;

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(iii) The assessing officers shall thereafter pass orders in terms of section 148A(d) in respect of each of the concerned assessees; Thereafter after following the procedure as required under section 148A may issue notice under section 148 (as substituted);

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(iv) All defences which may be available to the assesses including those available under section 149 of the IT Act and all rights and contentions which may be available to the concerned assessees and Revenue under the Finance Act, 2021 and in law shall continue to be available."

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In pursuance of aforesaid directions issued by the Apex

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Court, PAN INDIA which applied to the petitioner and the notice dated 30.06.2021 also, which was directed to be treated as a notice under Section 148AB of the Income Tax Act (as amended), the respondent furnished/provided information to the petitioner on 24.05.2022 and called upon the petitioner to file a reply on or before 07.06.2022. Since the petitioner did not file any reply to the aforesaid notice, the respondent proceeded to pass the impugned order dated 27.07.2022 under Section 148A(d) and simultaneously,

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HC-KAR

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issued a notice under Section 148 of the I.T Act on 28.07.2022. It is the specific contention of the petitioner that having regard to the aforesaid directions issued in Ashish Agarwal's case, the impugned order and notice had to be issued on or before 14.06.2022 and the same having been issued on 28.07.2022 was clearly barred by limitation as held by the Apex Court in the case of Union of India Vs. Rajeev Bansal 2024 INSC 754 and followed by various High Courts including the Gujarat High Court in the case of

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Southern Gujarat Chamber Trade and Industries Development Centre Vs. ITO Exemption - [2025] 179 taxmann.com. 55.

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Per contra, learned counsel for the respondent revenue submits that there is no merit in the petition and the same is liable to be dismissed.

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As rightly contented by the learned counsel for the petitioner, in the light of the undisputed fact that the respondents provided information to the petitioner pursuant to the judgment of the Apex Court in Ashish Agarwal's case on 24.05.2022, the period of limitation for passing the impugned order under 148A(d) and also issuance of notice under Section 148 which expired on

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HC-KAR

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14.06.2022 and consequently, the impugned order dated 27.07.2022 and notice dated 28.07.2022 were hopelessly and clearly barred by limitation as held in Rajeev Bansal's case as supra as hereunder:

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"110. The effect of the creation of the legal fiction in Ashish Agarwal (supra) was that it stopped the clock of limitation with effect from the date of issuance of Section 148 notices under the old regime [which is also the date of issuance of the deemed notices]. As discussed in the preceding segments of this judgment, the period from the date of the issuance of the deemed notices till the supply of relevant information and material by the assessing officers to the assesses in terms of the directions issued by this Court in Ashish Agarwal (supra) has to be excluded from the computation of the period of limitation. Moreover, the period of two weeks granted to the assesses to reply to the show cause notices must also be excluded in terms of the third proviso to Section 149.

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111. The clock started ticking for the Revenue only after it received the response of the assesses to the show causes notices. After the receipt of the reply, the assessing officer had to perform the following responsibilities: (1) consider the reply of the assessee under Section 149A(c); (ii) take a decision under Section 149A(d) based on the available material and the reply of the assessee; and (iii) issue a notice under Section 148 if it was a fit case for reassessment. Once the clock started

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HC-KAR

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ticking, the assessing officer was required to complete these procedures within the surviving time limit. The surviving time limit, as prescribed under the Income Tax Act read with TOLA, was available to the assessing officers to issue the reassessment notices under Section 148 of the new regime.

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112. Let us take the instance of a notice issued on 1 May 2021 under the old regime for a relevant assessment year. Because of the legal fiction, the deemed show cause notices will also come into effect from 1 May 2021. After accounting for all the exclusions, the assessing officer will have sixty-one days [days between 1 May 2021 and 30 June 2021] to issue a notice under Section 148 of the new regime. This time starts ticking for the assessing officer after receiving the response of the assessee. In this instance, if the assessee submits the response on 18 June 2022, the assessing officer will have sixty-one days from 18 June 2022 to issue a reassessment notice under Section 148 of the new regime. Thus, in this illustration, the time limit for issuance of a notice under Section 148 of the new regime will end on 18^th August 2022”.

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7. The aforesaid judgment in Rajeev Bansal's case has

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been followed by in Southern Gujarat Chamber Crates’s case supra as hereunder:

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"Heard learned Advocate Mr. Manish J. Shah for the petitioner and learned Senior Standing Counsel Ms. Maithili D. Mehta for the respondent.

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HC-KAR

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2. This petition is filed under Article 226 of the Constitution of India challenging the notice under section 148 of the Income Tax Act, 1961 (For short "the Act") dated 18.07.2022 on the ground that the notice would be invalid and time barred.

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3. Brief facts of the case are that the respondent Assessing Officer issued notice dated 29.06.2021 under section 148 of the Act for the Assessment Year 2016-2017 during the extended time period as per Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 [(2020) 422 ITR (St.) 116) (For short "TOLA").

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4. In view of the decision of Hon'ble Apex Court in case of Union of India v. Ashish Agarwal [2022] 138 taxmann.com 64/286 Taxman 183/444 ITR 1 (SC), the aforesaid notice was to be treated as notice under section 148A(b) of the Act which has come into statute with effect from 01.04.2021.

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5. The Hon'ble Apex Court in case of Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) has laid down the law to consider such notice as valid notice or invalid notice depending upon the surviving time left between the date of issuance of notice under section 148 of the Act read with section 3(1) of TOLA upto 30.06.2021 and the issuance of notice under section 148 pursuant to the directions issued by the Hon'ble Apex Court in case of Ashish Agarwal (supra).

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6. This Court in case of Dhanraj Govindram Kella v. ITO [2025] 177 taxmann.com 194 (Guj) (Judgment dated

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HC-KAR

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08.07.2025 rendered in Special Civil Application No.6387 of 2023 and allied matters) has considered in detail the submissions made by both the sides and has held as under:

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"65. The alternative contention of the petitioner as to whether notices would be valid notice or invalid notice considering 'surviving time' between the date of the issuance of notices under TOLA and 30th June, 2021 or not is required to be considered and for that each matter has to be considered separately on the basis of the facts of case considering the date of issuance of notices under section 148 under TOLA by the Revenue and thereafter date of supplying information to the assessee and date of passing of order under section 148A(d) and date of issuance of notice under section 148 of the Act so as to consider whether issuance of notice under section 148 of the Act is within 'surviving time' as per the direction of Hon'ble Apex Court in case of Rajeev Bansal (supra) or not.

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66. So far as Assessment Years 2013-2014 and 2014-2015 are concerned, the period of three years from the end of the assessment year would be over prior to 20.03.2020 and the period of six years would be over between 20.03.2020 and 30.06.2021. Therefore, the notices issued under section 148 of the Act under old regime between 01.04.2021 and 30.06.2021 as per TOLA, will be a valid notice if the notice under section 148 of the Act under new regime is issued within the period of 'surviving time' as per the directions issued by Hon'ble Apex Court in case of Rajeev Bansal (supra). For the Assessment Years 2016-2017 and 2017-2018 are concerned, the notice issued under section 148 of the Act under old regime between 01.04.2021 and 30.06.2021 under TOLA would be considered to be issued within three years from the end of the relevant assessment year as three years would complete within the period of 20.03.2020 and 30.06.2021.

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67. Therefore, in facts of these petitions, following data is required to be considered to find out 'surviving time' to decide as to whether the impugned notices under section 148 of the Act issued under the new regime as per the decision of Hon'ble Apex Court in case of Ashish Agarwal (supra) would be valid notice or not in view of the decision of the Hon'ble Apex Court in case of Rajeev Bansal (supra):

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HC-KAR

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SCA NO	AY	Date of notice under section 148 under TOLA	No of days of surviving time available till 30.06.2021	Date of providing information under section 148A(b)
6387/2023	2013- 2014	17.06.2021	13	26.05.2022
5688/2023	2014- 2015	09.06.2021	21	23.05.2022
22260/2022	2016- 2017	30.06.2021	1	23.05.2022
996/2023	2017- 2018	30.06.2021	1	24.05.2022

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SCA NO	Due date of filing reply	Date of reply:-	Date of order under section 148A(d) and notice under section 148:-	Last date for issuance of notice under section 148 as per surviving time:-
6387/2023	09.06.2022	04.06.2022	29.07.2022	22.06.2022
5688/2023	06.06.2022		27.07.2022	27.06.2022
22260/2022	07.06.2022	06.07.2022	30.07.2022	14.06.2022
996/2023	11.06.2022	10.06.2022	19.07.2022	18.06.2022

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68. It is apparent from the above details that impugned notice under section 148 of the Act is issued beyond the period of 'surviving time' as per the direction of Honble Apex Court in case of Rajeev Bansal (supra) and therefore, such notices would be invalid notices.

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69. The impugned notices issued under section 148 of the Act are accordingly quashed and set aside being invalid having been issued beyond the 'surviving time'. Accordingly, impugned orders passed under section 148A(d) of the Act would also not survive and are accordingly, quashed and set aside. Subsequent proceedings, if any, undertaken by the respondent would not survive and are also quashed and set aside.

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HC-KAR

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70. Rule is made absolute to the aforesaid extent. No order as to costs.

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7. In the facts of the case, the respondent Assessing Officer has provided information pursuant to the directions issued by the Hon'ble Apex Court in case of Ashish Agarwal (supra) on 27.05.2022 and therefore, considering 15 days' time to file reply by the assessee, the due date would be 10.06.2022. The petitioner filed reply on 01.06.2022. The order under section 148A(d) of the Act was passed on 15.07.2022 and notice under section 148 of the Act was issued on 18.07.2022. However, considering the period of limitation from the date of issuance of notice under section 148 read with TOLA upto 30.06.2021, the limitation for issuance of notice under section 148 of the Act applying the decision of Hon'ble Apex Court in case of Ashish Agarwal (supra) as well as Rajeev Bansal (supra), would be 17.06.2022.

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8. Learned Senior Standing Counsel Ms. Maithili D. Mehta has verified the above dates and could not controvert the same.

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9. In view of above, the impugned notice dated 18.07.2022 issued under section 148 of the Act would be invalid notice as the said notice is issued after 17.06.2022 as per the decision of Hon'ble Apex Court in case of Ashish Agarwal (supra). Therefore, the impugned notice having been issued beyond the 'surviving time' would be invalid notice as held by the Hon'ble Apex Court in case of Rajeev Bansal (supra) in the following paragraph no. 114 (g) and (h) of the judgment:

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HC-KAR

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"114. In view of the above discussion, we conclude that:

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XXX

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(g) The time during which the show-cause notices were deemed to be stayed is from the date of issuance of the deemed notice between April 1, 2021 and June 30, 2021 till the supply of relevant information and material by the Assessing Officers to the assessees in terms of the directions issued by this court in Union of India v. Ashish Agarwal ((2022) 444 ITR 1 (SC); (2023) 1 SCC 617.], and the period of two weeks allowed to the assessees to respond to the show-cause notices; and

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(h) The Assessing Officers were required to issue the reassessment notice under section 148 of the new regime within the time limit surviving under the Income-tax Act read with the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. All notices issued beyond the surviving period are time barred and liable to be set aside."

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10. In view of foregoing reasons, impugned order dated 15.07.2022 and impugned notice dated 18.07.2022 is hereby quashed and set aside and all consequential proceedings are also quashed and set aside.

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Similar view has been taken by High Court of Delhi and other High Courts. Under these circumstances, I am of the considered opinion that the impugned order and notices at Annexures- A, A1, A2, A3, A4, A5, A6, A7, A8, A9 and A10 deserve to be quashed.

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HC-KAR

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In the result, I pass the following:

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ORDER

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(i) Petition is hereby allowed.

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(ii) The impugned orders/ Notices at Annexures- A, A1, A2, A3, A4, A5, A6, A7, A8, A9 and A10 dated 30.06.2021, 24.05.2022, 27.07.2022, 28.07.2022, 28.07.2022, 02.11.2022, 29.05.2023, 16.10.2023, 20.10.2023, 31.10.2023 and 15.11.2023 respectively passed/issued by the respondents are hereby quashed.

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Sd/(S.R.KRISHNA KUMAR) JUDGE

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Srl.

Cite this judgement

Bhulakshmi House Building Co. Operative Society R v. Income Tax Officer, WP/2496/2025 (KA), decided on 18 December 2025.

The High Court of Karnataka publishes no neutral citation for this judgement — cite it by case number and date of decision.

Cases cited4

Union of India vs. Ashish AgarwalApplied¶49
Union of India Vs. Rajeev BansalFollowed¶62
Southern Gujarat Chamber Trade and Industries Development Centre Vs. ITO ExemptionFollowed¶63

View all cases cited

Statutes19

Constitution of IndiaArticles 226 and 227
Karnataka Co-operative Societies Act 1959Section 8
Income Tax ActSection 148 · 148A(b) · 148A(a) · 148A(d) · 149 · 149A(c) · 149A(d) · 148AB (as printed) · Section 147 read with Section 144 · Section 1448 (as printed) · 271(1)(b) · 271F · 2718 (as printed) · 271(1)(c)
Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA)Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 · 3(1)

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Procedural history4

Chain of eleven notices/orders for AY 2013-14 sought to be quashed (Annexures A to A10): notice under s.148 dated 30.06.2021 (A); notice under s.148A(b) dated 24.05.2022 (A1); order under s.148A(d) dated 27.07.2022 (A2); notice under s.148 dated 28.07.2022 (A3); intimation letter dated 28.07.2022 (A4); intimation of procedure dated 02.11.2022 (A5); order under s.147 r.w.s 144 dated 29.05.2023 (A6); penalty orders dated 16.10.2023, 20.10.2023, 31.10.2023 and 15.11.2023 (A7-A10).Respondent No.1 (Income Tax Officer, Ward-1(1), Mysore) and Respondent No.2 (National Faceless Assessment Centre), Income Tax Department · 30.06.2021 to 15.11.2023
For AY 2013-14, Respondent No.1 issued a notice dated 30.06.2021 under Section 148 of the Income Tax Act, before the provisions were amended effective 01.04.2021.
Following the Supreme Court's directions in Union of India v. Ashish Agarwal, the 30.06.2021 notice was directed to be treated as a deemed show-cause notice under Section 148A(b); the respondent furnished/provided information and material to the petitioner on 24.05.2022, calling for a reply on or before 07.06.2022.

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Bench / Coram

S.R. Krishna Kumar

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Bhulakshmi House Building Co. Operative Society R v. Income Tax Officer

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Bhulakshmi House Building Co. Operative Society R v. Income Tax Officer

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