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2023 (8) TMI 1419 - BOMBAY HIGH COURTValidity of reopening notices issued u/s 148 and orders passed u/s 148A(d) - authority which sanctioned for issuance of order u/s 148A(d) is the authority under Section 151(i) and not under Section 151(ii) - HELD THAT:- Admittedly, in these cases also the authority which sanctioned for issuance of order u/s 148A(d) is the authority under Section 151(i) and not under Section 151(ii) of the Act. As held in Siemens Financial Services Pvt Ltd. Vs. Deputy Commissioner of Income Tax Circle-8(2)(1) & Ors. [2023 (9) TMI 552 - BOMBAY HIGH COURT] the sanction ought to have been granted under Section 151(ii) and not under Section 151(i) of the Act. This applies to these petitions as well. Therefore, orders passed under Section 148A(d) as well as notices issued under Section 148 of the Act are hereby quashed and set aside.
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