ORDER

PRONOUNCED ON                                     ::                                                  25/10/2024

 (PER HON’BLE THE CHIEF JUSTICE):

1. In these petitions, prayer for stay of effect and operation of the impugned assessment orders and demand notices has been made on common grounds and submissions.

2. The impugned assessment orders and demand notices have been issued after reassessment carried out under Section 148 of the Income Tax Act, 1961 (for short ‘the Act of 1961’) in relation to Assessment Years 2012-13, 2013-14, 2014-15, 2015-16, 2016- 17, 2017-18, 2018-19 and 2019-20.

3. Learned counsel for the petitioner argued that reopening of assessment in all the cases is barred by limitation as under the new regime of law, after 01.04.2021, reopening under Section 148 of the Act of 1961 would not be permitted in a case for the relevant assessment year beginning on or before 1st day of April, 2021, if a notice under Section 148, or Section 153A, or Section 153C of the Act of 1961, could not have been issued at that time on account of being beyond the time limit specified under the provisions of sub-sec