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TMI Blog2024 (3) TMI 1082X X X X Extracts X X X X X X X X Extracts X X X X ..... on 147 of the Act and the same is required to be examined. If the AO who had sought the approval, the Additional/Joint CIT, who had recommended grant of approval and the PCIT, who granted the approval had only bothered to read the request for approval along with draft of the order under Section 148A(d) of the Act, they would have certainly noticed the discrepancies. It is, therefore, clear that none of these officers have even bothered to read the request for approval or draft of the order. In the affidavit in reply, it is mentioned as a typographical error. We are not inclined to accept this explanation because a typographical error could have been committed by the AO, who was seeking the approval, but if only the Additional/Joint CIT or t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ransactions during the relevant year were done by Petitioner being the transferee company but certain third parties have inadvertently booked the transactions with Petitioner in the erstwhile PAN of IGSPL and the said transaction are reflected in the 26AS of IGSPL. Petitioner has, however, considered all the transactions entered into by Petitioner in its return of income ("ROI") irrespective of whether the transactions have been booked in PAN of Petitioner or IGSPL and claimed credit of all TDS irrespective of whether tax has been deducted in the PAN of Petitioner or IGSPL. 4. Petitioner, thereafter, received notice dated 21st March 2023 under Section 148A(b) of the Act from Respondent No. 1. In the notice it was stated, inter alia: "it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Section 151 of the Act. 6. Various grounds has been raised in the petition, but the most important ground is that the sanction/approval under Section 151 of the Act has been obtained and granted without application of mind. We would agree with Petitioner. A copy of the approval and impugned order under Section 148A(d) are annexed to the petition. In column 7 of the approval, the quantum of income which has escaped assessment is mentioned as Rs. 63,16,784/-. In column 18, reasons for the belief that income has escaped assessment is answered as, "Refer order under Section 148A(d) for details". The Additional/Joint Commissioner of Income Tax Rameshwar Prasad Meena has recommended the issuance of notice under Section 148 and in Column 22, rea ..... X X X X Extracts X X X X X X X X Extracts X X X X
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