2024 (4) TMI 1384

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.... 1. Mr. Abhishek Mishra undertakes to file vakalatnama. 2. This petition relates to Assessment Year 2018-2019. 3. 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 5th April 2022 and the notice dated 17th March 2022 issued under Section 148A(b) of the Act. One of the grounds rai....

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....018-2019 and since the impugned order as well as the notice are issued on 5th 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, therefore, shall not be applicable to the matter at han....