2026 (3) TMI 383

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....a Saini, Sr. DR ORDER PER MANISH AGARWAL, AM: This appeal is filed by the Assessee against the order of the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi ['Ld. CIT(A)' in short], in Appeal No. NFAC/2016-17/10290719 dated 27.03.2025 passed u/s 250 of the Income Tax Act, 1961 ('the Act' in short) arising out of the assessment order passed u/s 147 r.....

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....lable on record. Form the perusal of the fresh notice issued u/s 148 of the Act after passing the order u/s 148A(d) on 28.07.2022, it is observed that the same were issued after obtaining the approval from the Pr. Commissioner of Income Tax-01, Delhi accorded on 27.07.2022 vide reference No.966. 4. Section 148 of the Act was substituted by the Finance Act, 2021 w.e.f. 01.04.2021 and the notice ....

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..... As per amended section 151 of the Act, if more than three years have lapsed from the end of the relevant assessment year, approval of Principal Chief Commissioner of Income-tax or Principal Director General or Chief Commissioner or Director General is mandatorily be obtained before the issue of notice u/s 148 of the Act. In the present case since the notices u/s 148 was issued on 28.07.2022 for ....

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....hree years from the end of the relevant assessment year, thus, in terms of Section 151(ii) of the Act, the same was required to be approved by the Principal Chief Commissioner or Principal Director General or where there is no such authority, by Chief Commissioner or Director General. The determination of the specified authority for grant of approval under Section 151 of the Act depends on whether....