2024 (2) TMI 1632

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....ndra Singh. For the Respondents : Mr. Akhileshwar Sharma. PC:- 1. Petitioner is impugning a notice dated 15th March 2022 issued under Section 148A(b) of the Income Tax Act, 1961 ("the Act"), the order dated 5th April 2022 passed under Section 148A(d) of the Act and the notice dated 6th April 2022 issued under Section 148 of the Act. One of the grounds raised is that the sanction to pass t....

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....6th April 2022, both state that the Authority that has accorded the sanction is the PCIT, Mumbai 5. The matter pertains to Assessment Year ("AY") 2018-19 and since the impugned order as well as the notice are issued on 5th April 2022 and 6th April 2022, respectively, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided under Sec....