TaxTMI 
TaxTMI 
2019 (7) TMI 807
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....TICE J.B.PARDIWALA) 1 This Tax Appeal under Section 260A of the Income Tax Act, 1961 (for short,'the Act, 1961') is at the instance of the Revenue and is directed against the order passed by the Income Tax Appellate Tribunal, Ahmedabad dated 14th November, 2018 in the ITA No.1505/Ahd/2017 for the assessment year 200708. 2 The Revenue has proposed the following question: "Whether on ....
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....missioner of Income TaxII, Surat on 29.03.2014, as per her signature and date, but the notice u/s 148 of the Act is dated 28.03.2014. Therefore, it appears that notice was issued before the approval of the Commissioner of Income Tax. The record is scanned and reproduced below. "NO.SRT/ITO/WD6(1)/148/201314 DATE:28/03/2014 PAN ABDPJ6027E NOTICE UNDER SECTION 148 OF THE INCOME TAX ACT, 1....
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....g reasons for initiating proceedings under Section 147 of the Income Tax Act, 1961. 12 Whether the Add. CIT is satisfied on the reasons recorded by the AO that it is a fit case for issuance of notice u/s 148 of the I.T. Act. Yes, after perusal, I am satisfied on the reasons recorded by the AO that it is a fit case for issuance of notice u/s 148 of the Act. Sanction u/s 151 of the I.T. Act m....
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.... u/s 148 void ab initio. This ground is decided in favour of appellant." 4 The aforesaid finding of fact came to be affirmed by the Appellate Tribunal in the appeal preferred by the Revenue. The findings recorded by the Tribunal are as under: "With the assistance of the ld. Representatives, we have gone through the record carefully, Section 151 of the Income Tax Act, 1961 contemplates that no....