TaxTMI 
TaxTMI 
2021 (11) TMI 710
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....r Petitioner. Mr. Suresh Kumar for Respondents. P. C. :- 1. When the Petition was filed, Petitioner had sought quashing of a notice dated 25/06/2019 issued by Respondent No.1 under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') and consequent proceedings initiated pursuant thereto under Section 147 of the Act. During the pendency of this Petition, an inter....
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....n of the Range 1(3), Mumbai'. Copy of approval at Exh.E to the Petition in which the Additional CIT, Range 1(3), Mumbai has, by hand noted, "Yes, I am satisfied that it is fit case for the issue of notice u/s 147 of the Act - Sd/- 26/06/2019". 4. Mr. Kamat submitted that if this necessary satisfaction / approval was granted only on 26/06/2019, how did Respondent No.1 issue notice under Section 14....
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....ar stated in Court today. In the objection dated 17/09/2021, Petitioner has brought to the notice of the Assessing Officer that notice issued under Section 148 dated 25/06/2019 was illegal and was issued without approval of competent authority and approval dated 26/06/2019 was an afterthought to cover up the action of the learned Deputy CIT. In the order dated 21/09/2021 rejecting this objection, ....