2023 (9) TMI 1547

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....dha Halbe. For the Respondents-Revenue : 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 a....

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....hat the approval has been granted by one Leena 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 b....

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.... the officers mechanically and without application of mind. There is not even an attempt to explain in the affidavit in reply as to how this error has been committed. We are of the opinion that if only the PCIT had read the Form for approval carefully, she would not have come to the conclusion that there is any material to treat it as a fit case to issue notice under Section 148 or pass order unde....