2022 (4) TMI 1530

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.... For the Respondents-Revenue : Mr. Akhileshwar Sharma. P.C. : 1. The issue in the petition pertains to A.Y. 2015-16 and one of the primary grounds taken to challenge re-opening proposed is invalid approval under Section 151 of the Income Tax Act, 1961 (the Act). Mr. Sharma tenders affidavit of one Mr. Pradeep Sharma, Deputy Commissioner of Income Tax, Circle 3(3)(1), Mumbai affirmed on 26....

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....ommissioner or Principal Commissioner or Commissioner who could have accorded the approval and not the Joint Commissioner of Income Tax. On this ground alone, we will have to set aside the impugned notice dated 26th March, 2021. Consequently, the order on objections passed on 6th February, 2022 also has to be quashed and set aside. 2. Petition is allowed in terms of prayer clause - (a), which r....