TaxTMI 
TaxTMI 
2018 (11) TMI 1648
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...., JUDICIAL MEMBER: Revenue is in appeal before the Tribunal against order of ld. CIT(A)-3, Surat dated 29. 03. 2017 for the Asstt. Year 2007-08. 2. Revenue has taken four grounds of appeal, out of which ground no. 1 and 2 are the substantial grounds. In ground no. 2, it has pleaded that the ld. CIT(A)has erred in holding that notice under section 148 of the Income Tax Act, 1961 issued by the A....
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....gly, he recorded reasons and issued notice on 28. 3. 2014 which was stated to be served upon the assessee on 23. 3. 2014 (this date has been mentioned in the assessment order). The ld. AO thereafter framed assessment order on 5. 3. 2015 under section 143(3) r.w.s. 147 of the Act. He made addition of Rs. 43,09,98,411/-. Dissatisfied with the assessment order, the assessee carried the matter in appe....
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....h the record carefully. Section 151 of the Income Tax Act, 1961 contemplates that no notice under section 148 shall be issued by the Assessing Officer, after the expiry of a period of four years from the end of the relevant assessment year, unless necessary approval from Commissioner or competent authority is obtained. No doubt in the present case, the ld. AO has applied for such approval which wa....