Bombay HC stayed Section 148 proceedings for AY 2014-15

Narendra Gangadas Kanakia Vs Union of India (Bombay High Court) Hon’ble Bombay High Court has stayed the proceedings under Section 148 of the Income Tax Act 1961 for AY 2014-15. The initial notice was issued after the time limit under old Section 148 expired. However on the basis of the judgment of the Supreme Court in Union of India v Ashish Agarwal, the old Section 148 notice was treated as show cause notice under the new Section 148A(b). A circular (Instruction dated 11 May 2022) was also issued by CBDT wrongly reading the judgment of the Supreme Court as allowing reopening for AY 201...