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TMI Blog2025 (1) TMI 1123X X X X Extracts X X X X X X X X Extracts X X X X ..... seas Pvt. Ltd. [ 2022 (12) TMI 702 - SC ORDER ] we are inclined to quash 148 proceedings as bad in law. Accordingly, ground is allowed. X X X X Extracts X X X X X X X X Extracts X X X X ..... ere initiated by the AO, however same was not disposed off. He submitted that the reasons recorded in the notice u/s 154 are exactly similar to the reasons recorded for reopening the assessment. He brought to our notice Annexure-1 submitted which is an approval form for initiating the proceedings u/s 148 submitted by the AO before the ACIT. As per the reasons recorded in the approval form, the reasons recorded therein are exactly similar to the reasons recorded in the notice issued u/s 154 proceedings. In this regard, he submitted that the issue under consideration is covered and brought to our notice decision of Hon'ble Supreme Court in the case of SM Overseas Pvt. Ltd. vs. CIT in Civil Appeal Nos.3612-3613 of 2012 dated 7th December, 2022 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eriod of limitation prescribed under Section 154(7) of the Act. In the absence of any specific order of withdrawal of the proceedings under Section 154 of the Act, the proceedings initiated under Section 154 of the Act can be said to have been pending. In that view of the matter, during the pendency of the proceedings under Section 154 of the Act, it was not permissible on the part of the Revenue to initiate the proceedings under Section 147/148 of the Act pending the proceedings under Section 154 of the Act. The High Court has erred in presuming and observing that the proceedings under Section 154 were invalid because the same were beyond the period of limitation." 6. Respectfully following the above decision, we are of the view that in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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