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The High Court upon their reference to Apex Court decision in Union of India v. Ashish Agarwal [2022] 444 ITR 1 (SC) held that the Supreme Court therein only partly allowed the appeals of the Union of India in so far as notices issued u/s148 by the Department on or after April 1, 2021.

As in this case the same was issued on March 30, 2021, i. e., prior to April 1, 2021 for AY 2013-14 the same got quashed since it was beyond the period of six years after the expiry of the assessment year. 

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