2024 (8) TMI 180

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....la a / w Mr. Harsh Kothari for Petitioner in WP / 3249 / 2022 Mr. Akhileshwar Sharma , for Respondents - Revenue ORDER P C : - 1. This petition relates to Assessment Year 2018- 2019. 2. Petitioner is impugning a notice issued under Section 148 of the Income Tax Act, 1961 ("the Act") and the order passed under Section 148A(d) of the Act, both dated 22nd April 2022 and the notice date....

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.... sanction is the PCIT, Mumbai-5. The matter pertains to Assessment Year ("AY") 2018-2019 and since the impugned order as well as the notice are issued on 22nd April 2022, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided under Section 151(ii) of the Act. The proviso to Section 151 of the Act has been inserted only with effect....