2024 (3) TMI 1479

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.... Gandhi, with Ms. Anchal Vyas. For the Respondents-Revenue : Mr. Suresh Kumar. ORDER PC :- 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 7th April 2022 and the notice dated 21st March 2022 issued under Sectio....

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....The matter pertains to Assessment Year ("AY") 2018-2019 and since the impugned order as well as the notice are issued on 7th 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 from 1st April 2023 and, therefor....