2022 (4) TMI 1555

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....ructed by Mr. Kumar Kale. For the Respondents : Mr. Suresh Kumar. P.C. :- 1. Paragraphs 1 and 2 of Order dated 25th January, 2022 reads as under : ".Mr. Ginde, for Petitioner submits that as per notice dated 31st March, 2021 issued under section 148 of the Income Tax Act, 1961 (the said Act) by Respondents for A.Y. 2015-2016, the proposed reopening is after the expiry of four yea....

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....can take instructions and also file affidavit in reply if required, in the meanwhile." 2. No reply has been filed till date. 3. Copy of the approval granted under Section 151 of the Income Tax Act, 1961 (the said Act) is placed on record. The approval has been given by one Mr. Pankaj Kumar, Range 1(1), Mumbai. Exhibit - E to the Petition is a copy of a letter dated 31st March, 2021 addressed....

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....ng on 31st March 2020 stood extended to 31st March 2021 and in view thereof, for the Assessment Year 2015-2016 which falls under the category within four years as on 31st March 2020, the statutory approval for issuance of notice under Section 148 of the Act was given by the Additional Commissioner. 5. Even if for a moment, we agree with Mr. Suresh Kumar, still it applies to only cases where the....