2021 (9) TMI 1584

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....Pawan Kumar Chakrapani. For the Revenue : Shri Sunku Srinivas. (D.R.) ORDER Per Shri S.S. Godara, J.M. : This Revenue's appeal and assessee's Cross Objection ITA No.887 and 59/Hyd/2015 for assessment year 2009-10 arise from the Commissioner of Income Tax (Appeals)-5, Hyderabad's order dt.16.03.2015 passed in case No.0657/2014-15/CIT(A)-5 in proceedings under Section 143(3) r.w.s. 1....

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....gular assessment framed on 5.12.2011 and his 154 rectification notice issued on 2.12.2012. Case records indicate that the Assessing Officer thereafter formed reasons to believe that the assessee's taxable income liable to be assessed has escaped assessment. He thus issued 148 notice dt.10.03.2014 i.e. well before the expiry of four years from the end of the relevant assessment year coming to 3....

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....ioner or Chief Commissioner or Principal Commissioner or Commissioner is satisfied, on the reasons recorded by the Assessing Officer, that it is a fit case for the issue of such notice. (2) In a case other than a case falling under sub-section(1), no notice shall be issued u/s. 148 by an Assessing Officer, who is below the rank of Joint Commissioner, unless the Joint Commissioner is satis....