2023 (9) TMI 1547

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....enue : Mr. Manoj Shirsat. ORDER P.C. : 1 Petitioner is impugning an order dated 20th April 2023 passed under Section 148A(d) of the Income Tax Act, 1961 (the Act) and notice dated 20th April 2023 issued under Section 148 of the Act on various grounds, one of which is that the approval under Section 151 of the Act has been granted mechanically without application of mind. The averments to that....

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....ena Srivastava, PCIT, on 19th April 2023. 3 Having perused the approval Form, it is quite obvious that the person seeking the approval has not applied his mind and the PCIT granting approval also has not applied her mind. This is because the time limit for current proceedings should be covered under Section 149(1)(a) that is for less than three years because the assessment year is 2019-2020 and t....