2026 (2) TMI 88

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....e Respondent : Ms. Pooja Swaroop, CIT, DR ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the assessee against the order dated 25.03.2025 of the Ld. National Faceless Appeal Centre (NFAC) Delhi (hereinafter referred as Ld. First Appellate Authority or in short Ld. 'FAA') in DIN & Order No : ITBA/NFAC/S/250/2024-25/1075010446(1)arising out of the order dated 19.05.2023 u/s 147 r.....

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....2 while the law stands settled that as approval sought to have been taken of Principle Chief Commissioner of Income Tax and that vitiates the approval. Reliance is placed of the decision of Hon'ble Supreme Court in the case of Union of India Vs. Rajiv Bansal (2024) 10 TMI 264 which has been relied by this Bench in ITA No. 1899 & 1900/Del/2025 order dated 29.07.2025 in para 3 & 4 which is reproduce....

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....sessing officers to issue a notice under Section 148 of the new regime "after following the procedure as required under Section 148-A." Although this Court waived off the requirement of obtaining prior approval under Section 148A(a) and Section 148A(b), it did not waive the requirement for Section 148A(d) and Section 148. Therefore, the assessing officer was required to obtain prior approval of th....