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ITAT quashed notice issued u/s. 148 as invalid and allowed the appeal of the assessee. Relying on the Supreme Court's exposition that the pre-conditions in s.151 are mandatory, the Tribunal held that grant of sanction by an appropriate authority is a jurisdictional prerequisite for the AO to assume jurisdiction and issue a s.148 notice. The impugned s.148A(d) order and final notice dated 06/04/2022 were issued with purported prior sanction by the PCIT, who lacked authority to grant such sanction; statutory sanction was required to be by the Pr. CCIT or the CIT. For this defect alone, the notice was held void and quashed.
ITAT quashed notice issued u/s. 148 as invalid and allowed the appeal of the assessee. Relying on the Supreme Court's exposition that the pre-conditions in s.151 are mandatory, the Tribunal held that grant of sanction by an appropriate authority is a jurisdictional prerequisite for the AO to assume jurisdiction and issue a s.148 notice. The impugned s.148A(d) order and final notice dated 06/04/2022 were issued with purported prior sanction by the PCIT, who lacked authority to grant such sanction; statutory sanction was required to be by the Pr. CCIT or the CIT. For this defect alone, the notice was held void and quashed.
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