2024 (8) TMI 286

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..... instead of Principal Chief Commissioner of Income Tax (PCCIT) u/s 151(ii) - HELD THAT:- Petitioner is correct in saying that the AY is 2018-19 and, therefore, since more than three years have expired from the end of the assessment year, Sanctioning Authority u/s151(ii) of the Act should be the Principal Chief Commissioner of Income Tax ( PCCIT ) and not the PCIT. As held in Siemens Financial Servi .....

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..... under Section 148A(b) of the Act. Various grounds have been raised but one of the primary grounds for challenging the notice under Section 148A(d) and the notice under Section 148 of the Act both dated 7th April 2022 is that order as well as the notice both mention the authority that has granted approval, is the Principal Commissioner of Income Tax ( PCIT ), Mumbai 5 and the approval has been gran .....

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