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Hello friends in the YouTube channel Advocate Amit Kumar Gupta today I am going to discuss the case of harshit foundation versus Commissioner of income tax this case has been reported in 447 ITR at page number 372 the matter has been decided by The Honorable Supreme Court and the date of the judgment is apprent 22 2022 friends we have seen that whenever some timelines are given into the ACT where the assessing authorities have to act they are very lazy to react and as per my experience timeliness doesnt mean anything for the income tax authorities they are just for the SSC for example when we file section 154 application when we file lower TDS certificate applications when we file section 12a registration active application and apart from this when the question of issuing the notices under Section 148 comes the department crosses all its limits in delaying the issuing of the notices we have seen it is our experience that the notices are issued at the end that is 30th or 31st March an