TMI Blog2022 (3) TMI 1414X X X X Extracts X X X X X X X X Extracts X X X X ..... nt. We further note that approval under Section 151 of the Act also has been given on the same reasons, which would also indicate total non application of mind by not only the JAO but also by the Revenue Head who had recommended the case to the Principal CIT and also Principal CIT himself. One thing is evident that the approval is granted in a mechanical way without applying their mind. Petition is allowed in terms of prayer clause (a) and (b) which reads as under : This Hon ble Court may be pleased to issue under Article 226 of the Constitution of India an appropriate direction, order or a writ, calling for the records of the case and after satisfying itself as to the legality thereof quash and set aside the notice issued by the Re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome Tax Department has collected information about taxpayers from various sources such as Annual Information Return (AIR), Central Information Branch (CIB), Tax Deduction at Source (TDS) Statement and information uploaded by Investigation Wings/Central Circle/I CI on Insight Portal. As per the information summary available in Insight Portal, the following information relating to Assessment Year 2013-14 pertains to the assessee company. Sr. No. Source of PAN Source of PAN Name Information F.Y. Information Type Information Value 1 AABCR3382E ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ind by not only the JAO but also by the Revenue Head who had recommended the case to the Principal CIT and also Principal CIT himself. One thing is evident that the approval is granted in a mechanical way without applying their mind. 5. In the circumstances, petition is allowed in terms of prayer clause (a) and (b) which reads as under : (a) that this Hon ble Court may be pleased to issue under Article 226 of the Constitution of India an appropriate direction, order or a writ, calling for the records of the case and after satisfying itself as to the legality thereof quash and set aside the notice dated 31.03.2021 issued by the Respondent No.1 under section 148 of the Income Tax Act, 1961, being Ex.- J hereto; (b) that this Hon ..... X X X X Extracts X X X X X X X X Extracts X X X X
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