2024 (2) TMI 1570

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....ndhi. For Respondents-Revenue : Ms. Shilpa Goel. ORDER P.C. : 1 This petition relates to Assessment Year 2018-19. 2 Mr. Gandhi for petitioner states this petition is covered by the order dated 6th February 2024 passed by this court in the case of Vodafone Idea Limited Vs. Deputy Commissioner of Income Tax, Circle 5(2)(1), Mumbai & Ors. Ms. Goel for respondents agrees. 3 Petitione....

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.... 2018-19. Since the impugned order as well as the notice are both issued on 21st 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 has been inserted only with effect from 1st April 2023 and, therefore, shall not be applicable to the matter at hand. 5 ....