2026 (1) TMI 126

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....ed by the assessee is preferred against the order of the Ld.Commissioner of Income Tax /NFAC, Delhi [herein after referred as "CIT(A)"] dated 01.04.2025 for A.Y. 2018-19. 2. The assessee has raised following grounds of appeal :- "1. Sanction u/s 151 is mandatory before issue of 148 notice. Notice u/s 148 dt 01/04/2022 mention that sanction from PCIT, Ghaziabad was obtained. From asst. ....

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....o respond. Notice dt 22/03/2022 was prescribed to be responded by 29/03/2022 and the notice as per AO was sent by speed post. It must have been delivered at least 3 days later giving merely 2-3 days time to respond. It violates rule of principle of natural justice and is bad in law. 4. That notice u/s 148A(b) and 148 both were issued by jurisdictional assessing officer. U/s 151A CBDT had ....

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....e Act from the appropriate authority. Ld. Counsel for the assessee referring to copy of notice dated 01.04.2022 issued u/s.148 of the Act, submitted that the AO obtained prior approval of the PCIT, Ghaziabad for reopening the assessment for the A.Y.2018-19. The Ld. Counsel for the assessee submitted that the notice dated 01.04.2022 issued u/s.148 of the Act since beyond the period of three years f....

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....Vs. ITO in ITA No.2272/PUN/2024 dated 26.05.2025. 4. On the other hand the Ld. DR supported the orders of the authorities below. 5. Heard rival contentions and perused the orders of the authorities below and the case laws relied upon before us. It is an undisputed fact is that notice u/s.148 and also u/s. 148A were all issued for the A.Y.2018-19 after obtaining approval from PCIT, Ghaziabad.....