2024 (4) TMI 1222

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..... assessment year 2017-18. 2. The 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 July 20, 2022 and the notice dated May 25, 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 .....

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..... valid. The answer is "No". 4. The impugned order and the impugned notice both dated July 20, 2022 state that the authority that has accorded the sanction is the Principal Commissioner of Income-tax-27, Mumbai. The matter pertains to assessment year ("AY") 2017-18 and since the impugned order as well as the notice are issued on July 20, 2022, both have been issued beyond a period of three years. .....

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