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2022 Supreme(SC) 398

M. R. SHAH, B. V. NAGARATHNA
Union of India – Appellant
Versus
Ashish Agarwal – Respondent


Advocates appeared:
For the Appellant(s) :N. Venkataraman, ASG Santosh Kumar, Praneet Pranav, Raj Bahadur Yadav, Advocates
For the Respondent(s):C.A. Sundaram, Kavita Jha, Vaibhav Kulkarni, Anant Mann, Udit Naresh, Nishit Agrawal, Harsh Mishra, Upasna Agrawal, Mohit Kumar Bansal, Shubhakriti Gaur, Rakesh Gupta, Somil Agarwal, Ambhoj Kumar Sinha, Kapil Goel, Sandeep Goel, Dhananjay Garg, D. K. Garg, Abhishek Garg, Divyanshu Agrawal, Vaibhav Niti, Madhavi Agrawal, Abhinav Agrawal, Gaurav Jain, Akshita Goyal, Shubham Gupta, Archana Sahadeva, Abhinav Agrawal, Subodh S. Patil, Abhinav Merhotra, Kush Chaturvedi, Priyashree Sharma PH, Syed Faraz Alam, Advocates

JUDGMENT

M.R. Shah, J.

Leave granted in SLP (C) Nos. 6448/2022, 5381/2022, 5079/2022, 6092/2022, 6534/2022, 6158/2022, 6316/2022, 6281/2022, 6545/2022, 6038/2022.

1. Feeling aggrieved and dissatisfied with the impugned common judgment and order passed by the High Court of Judicature at Allahabad in Writ Tax No. 524/2021 and other allied writ tax petitions, by which the High Court has allowed the said writ petitions and has quashed several reassessment notices issued by the Revenue, issued under section 148 of the Income Tax Act, 1961, on the ground that the same are bad in law in view of the amendment by the Finance Act, 2021 which has amended Income Tax Act by introducing new provisions i.e. sections 147 to 151 w.e.f. 1st April, 2021, the Revenue has preferred the present appeals.

2. Similar judgments and orders are passed by various other High Courts including High Court of Delhi; High Court of Rajasthan; High Court of Calcutta; High Court of Madras; High Court of Bombay, the particulars


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