9911796707
TMI Blog2024 (8) TMI 180X X X X Extracts X X X X X X X X Extracts X X X X ..... Income Tax ( PCIT ) and not by the Principal Chief Commissioner of Income Tax (PCCIT ) - HELD THAT:- The impugned order and the impugned notice state that the Authority that has accorded the sanction is the PCIT, Mumbai-5. The matter pertains to AY 2018-2019 and since the impugned order as well as the notice are issued on 22nd April 2022, both have been issued beyond a period of three years. Ther ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2018- 2019. 2. Petitioner is impugning a notice issued under Section 148 of the Income Tax Act, 1961 ( the Act ) and the order passed under Section 148A(d) of the Act, both dated 22nd April 2022 and the notice dated 29th March 2022 issued under Section 148A(b) of the Act. One of the grounds raised is that the sanction to pass the order under Section 148A(d) of the Act and issuance of notice under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided under Section 151(ii) of the Act. The proviso to Section 151 of the Act has been inserted only with effect from 1st April 2023 and, therefore, shall not be applicable to the matter at hand. 5. In the circumstances, as held by this Court in Siemens Financial Services Private Limited Vs. Deputy Comm ..... X X X X Extracts X X X X X X X X Extracts X X X X
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