1 CGHC010275692022 2026:CGHC:38881 NAFR HIGH COURT OF CHHATTISGARH AT BILASPUR WPT No. 208 of 2022  Dr. Manish Bansal S/o - Shri S. C. Bansal, Aged About 47 Years R/o Bansal Nursing Home, Balaji Ward, Jagdalpur, District Bastar Chhattisgarh. ... Petitioner versus 1. The Commissioner Of Income Tax, Range-1, Central Revenue Bullding, Civil Lines, Raipur Chhattisgarh. 2. The Income Tax Officer, Ward-Jagdalpur, District Bastar Chhattisgarh. ... Respondent(s) For Petitioner : Mr. Vijay Shankar Mishra, Advocate For Respondents : Mr. Ajay Kumrani, Advocate holding the brief of Mr. Amit Chaudhari, Advocate Hon'ble Shri Justice Rakesh Mohan Pandey Order on Board 01.09 .2026 1. With regard to notices issued for assessment year 2015-16, in the matter of Union of India vs. Rajeev Bansal reported in (2024) 167 taxmann.com 70 (SC) considered before the Honb’le Supreme Court in para 19(f) as under :- “19 f. The Revenue concedes that for the assessment year 2015-16, all notices issued on or after 1 April 2021 will have to be dropped as they will not fall for completion during the period prescribed under TOLA.” 2. Further in the matter of Deepak Steel and Power Limited vs. Central Board SIDDHANT TAMRAKAR Digitally signed by SIDDHANT TAMRAKAR Date: 2026.09.02 14:50:17 +0530 2 of Direct Taxes & Ors. reported in 305 Taxman 169 (SC), the Hon’ble Supreme Court while dealing with the order passed under Section 148(A)(d) of the Income Tax Act, 1961 (for short “Act, 1961”) and notices issued under Section 148 of the Act, 1961 in para 5 held has under :- “5. As the revenue made a concession in the aforesaid decision that is for the assessment year 2015-16, all notices issued on or after 1st April, 2021 will have to be dropped as they would not fall for completion during the period prescribed under the taxation and other laws (Relaxation and Amendment of certain Provisions Act, 2020). Nothing further is required to be adjudicated in this matter as the notices so far as the present litigation is concerned is dated 25.06.2021.” 3. Taking into consideration the reassessment proceedings made by the revenue and observation made by the Hon’ble Supreme Court in the matter of Deepak Steel (supra) the order issued under Section 148 (A)(d) Act, 1961 and notice issued under Section 148 of Act, 1961 are hereby quashed. 4. With the aforesaid observation(s), and direction(s), the instant petition is hereby disposed of. Sd/- (Rakesh Mohan Pandey) JUDGE $iddhant