9911796707
TMI Blog2024 (2) TMI 1408X X X X Extracts X X X X X X X X Extracts X X X X ..... d not by the Principal Chief Commissioner of Income Tax (PCCIT ) - HELD THAT:- The matter pertains to Assessment Year ( AY ) 2018-19 and since the impugned order as well as the notice are issued on 7th April 2022, both have been issued 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 provisio to Section 151 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f 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 Section 148 of the Act is invalid inasmuch as the sanction has been admittedly issued by the Principal Commissioner of Income Tax ( PCIT ) and not by the Principal Chief Commissioner of Income Tax (PCCIT ). 2. Petitioner s request for a copy of the sanction has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ction 151 (ii) of the Act. The provisio to Section 151 has been inserted only with effect from 1st April 2023 and, therefore, shall not be applicable to the matter at hand. 4. In this circumstances, as held by this Court in Siemens Financial Services Private Limited Vs. Deputy Commissioner of Income Tax Ors., (2023) 457 ITR 647. (Bom.) the sanction is invalid and consequently, the impugned order a ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
