2025 (7) TMI 667

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....ngh, Sr. DR ORDER PER ANUBHAV SHARMA, JM: These appeals are preferred by the assessee against the orders dated 27.01.2025 of the Ld. Commissioner of Income-tax (Appeals)-27, New Delhi. 2. At the time of hearing, in regard to the appeal for AY 2016-17, the ld. AR has pointed out that the assessee was not duly served. The ld. DR has defended the order of the CIT(A) submitting that notices on var....

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....R, we find that in the present case, order u/s 148A(d) has been passed and, thereafter, notice u/s 148 has been issued. The order u/s 148A(d) has been passed and notice issued on 27.07.2022, i.e., after three years from the end of AY 2017-18. The Hon'ble Supreme Court in Union of India vs. Rajeev Bansal, 2024 (10) TMI 264, order dated 03.10.2024, has held in para 81 as follows:- "81. This Court ....

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....ed under Section 151 of the new regime read with TOLA, where applicable. 4. Thus, prior approval of Principal Chief Commissioner or Principal Director General and where these two authorities are not there, then, the Chief Commissioner or Director General are competent authorities to grant the approval. However, in the case in hand, such approval of these competent authorities have not been taken ....