Benefit of TOLA 2020 not available to first proviso to Section 149(1)(b) of Income Tax Act

Wallstone Ceramic Vs DCIT (Gujarat High Court) Gujarat High Court held that in respect of the proceedings where the first proviso to Section 149(1)(b) is attracted, the benefit of the Taxation and Other Laws (Relaxation And Amendment of Certain Provisions) Act, 2020 (TOLA 2020) will not be available to the revenue. Facts- In the present petitions filed under Article 226 of the Constitution, the respective petitioners have called in question the notice issued by respondent – assessing officer under Section 148 of the Income Tax Act, 1961 seeking to reopen the assessment in respect of asse...