IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED : 24.11.2025 CORAM :

THE HONOURABLE MR.JUSTICE C.SARAVANAN and W.M.P.Nos.26560, 26561, 26562, 26565, 26568, 26569, 31090 and 31097 of 2022 E2E Supply Chain Solutions Limited, Represented by its Director R.Vasudevan ... Petitioner in both W.Ps Vs.

1.The Assistant Commissioner of Income Tax, Corporate Circle-2(1), Chennai, Income Tax Department, 121, Nungambakkam High Road, Nungambakkam, Chennai – 600 034.

2.The Principal Commissioner of Income Tax, Chennai – 2, Income Tax Department, 121, Nungambakkam High Road, Nungambakkam, Chennai – 600 034. ... Respondents in both W.Ps Prayer in W.P.No.27362 of 2022: Writ Petition is filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, to call for the records of the Writ Petitioner on the file of the 1^st Respondent to quash the Impugned Order under Section 148A(d) of the Income Tax Act, 1961 dated 28.07.2022 in DIN and Order DIN and Order No.ITBA/COM/F/17/2022-23/1044233375(1) and consequential Notice issued under Section 148 of the Income Tax Act, 1961 dated 28.07.2022 in DIN and Document No.ITBA/AST/M/148-1/2022-

23/1044303105(1) for the Assessment Year 2016-17.

Prayer in W.P.No.27366 of 2022: Writ Petition is filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, to call for the records of the Writ Petitioner on the file of the 1^st Respondent to quash the Impugned Order under Section 148A(d) of the Income Tax Act, 1961 dated 28.07.2022 in DIN and Order DIN and Order No.ITBA/COM/F/17/2022-23/1044236013(1) and consequential Notice issued under Section 148 of the Income Tax Act, 1961 dated 28.07.2022 in DIN and Document No.ITBA/AST/M/148-1/2022-

23/1044307910(1) for the Assessment Year 2017-18.

For Petitioner : Mr.A.S.Sriraman (In both W.Ps)

For Respondents : Mr.Avinash Krishnan Ravi (In both W.Ps) Junior Standing Counsel

COMMON ORDER

Heard the learned counsel for the Petitioner and the learned Junior Standing Counsel for the Respondents.

2. In these Writ Petitions, the Petitioner has challenged the respective Section 148A(d) orders both dated 28.07.2022 passed by the 1^st Respondent and consequential Section 148 Notices issued under the new regime of the Income Tax Act, 1961 as in force with effect from 01.04.2021 for the Assessment Years

2016-2017 and 2017-2018.

3. The limitation for issuance of Section 148 Notices under the old regime as in force till 31.03.2021 for the aforesaid Assessment Years 2016-2017 and

2017-2018 expired on the following dates:-

2017-2018 expired on the following dates:-

2017-2018 expired on the following dates:-

2017-2018 expired on the following dates:-

2017-2018 expired on the following dates:-

2017-2018 expired on the following dates:-

[Note: *However, the 4 years stood extended to 30.06.2021 in view of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions)

Act, 2020 (TOLA).]

4. In these cases, the Petitioner was issued with Section 148 Notices on

29.06.2021 for both the aforesaid Assessment Years under the old regime as in force till 31.03.2021. This was ostensibly on account of extension of time for the Assessment Year 2016-2017 under the provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. Meanwhile, the Hon’ble Supreme Court rendered its decision on 04.05.2022 in Union of India and Others Vs. Ashish Agarwal, [2023] 1 SCC 617.

5. The decision of the Hon’ble Supreme Court in Ashish Agarwal case (cited supra) which was implemented by the Central Board of Direct Taxes (CBDT) vide Instruction No.01 of 2022 dated 11.05.2022 was re-examined by a larger bench of the Hon’ble Supreme Court in Union of India and others Vs.

Rajeev Bansal, [2024] 167 taxmann.com 70 SC / 2024 SCC Online SC 2693 vide its Order dated 03.10.2024 in Civil Appeal No.8629 of 2024

6. There, the Hon’ble Supreme Court framed the following issues for consideration:

(a)Whether the Taxation and Other Laws (Relaxation and Amendment