9911796707
TMI Blog2022 (5) TMI 339X X X X Extracts X X X X X X X X Extracts X X X X ..... titioner. Mr. Akhileshwar Sharma for the Respondent - Revenue. P.C. 1] Petitioner is impugning a notice dated 27.03.2021 issued under section 148 of the Income Tax Act, 1961 (the Act) for assessment year 2015-2016, issuance of impugned scrutiny notice dated 07.12.2021 and order dated 03.02.2022 rejecting petitioner's objections to reopening. 2] We would straightaway go to the sanction granted ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... notice issued is bad in law. Mr.Thakkar also submitted that there are various other grounds on which the impugned notices have been challenged which the Court may not have go into at this stage since the Court has in other matters held such sanction like the one granted in this petition will not amount to a valid sanction. 3] Sub-section 1 of section 151 provides that no notice shall be issued u ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5] Mr. Sharma submitted that in view of the Taxation and other Laws (Relaxation of Certain Provisions) Act, 2020 (Relaxation Act), limitation, inter alia, under provisions of section 151(1) and section 151(2), which were originally expiring on 31.03.2020 stand extended to 31.03.2021. According to Mr. Sharma, in view of the above, A.Y. 2015-2016 which falls under the category within four years as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , it is only the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner who could have accorded the approval and not the Additional Commissioner of Income Tax. On this ground alone, we will have to set aside the notice dated 31.03.2021 issued under section 148 of the Act, which is impugned in this petition. In view thereof, the consequent orders and notices wi ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
