9911796707
TMI Blog2022 (4) TMI 1555X X X X Extracts X X X X X X X X Extracts X X X X ..... he case at hand, the approval ought to have been given by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner and not by the Additional Commissioner of Income Tax. We find support for this view in judgment of this court in Voltas Ltd. Vs. ACIT [ 2022 (4) TMI 594 - BOMBAY HIGH COURT] and J.M. Financial and Investment Consultancy Services Pvt. Ltd. [ 202 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Principal Commissioner or Commissioner. 2. Mr. Ginde further submitted that as could be seen from the approval under section 151 of the Act along with a letter dated 31st March, 2021 from the Additional CIT Range 1(1) addressed to the Income Tax Officer, Ward 1(1)(3), the approval has been granted by Additional CIT and therefore the sanction as required under section 151 of the Act, has not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1), Mumbai. Mr. Suresh Kumar also confirms that Mr. Pankaj Kumar is the Additional CIT who has granted the approval. 4. According to Respondents the case at hand is within four years from the end of the assessment year under consideration, in view of extension of limitation date due to Covid situation. The Assessing Officer has not explained in the reasons recorded as to how the limitation date ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re only on 31st March 2022. Therefore, the Relaxation Act provisions cannot be applicable. Even if, the time to issue notice is considered to have been extended, that would not amount to amending the provisions of Section 151 of the Act. 6. In our view, for the case at hand, the approval ought to have been given by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner ..... X X X X Extracts X X X X X X X X Extracts X X X X
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