(PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA)
1. Heard learned advocate Mr. Fenil H.
Mehta for the petitioner and learned
Senior Standing Counsel Mr. Karan G.
Sanghani for the respondents.
2. The petitioner has challenged notices
issued under section 148 of the Income Tax
Act, 1961 (for short “the Act”) for the
NEUTRAL CITATION
C/SCA/5561/2023 ORDER DATED: 25/08/2025
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Assessment Year 2015-2016 under the old
regime in view of TOLA without issuing
notice under section 148A(b) as required
to be issued with effect from 01.04.2021.