Notices under Section 148 of the Income Tax Act issued beyond prescribed limitation are invalid as per Supreme Court directives.

ORDER :

S.R.KRISHNA KUMAR, J.

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

“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.

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.

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

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.

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.

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.

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.

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.

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.

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.

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.

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

2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record.

3. A perusal of the material on record will indicate that in relation to the assessment year