2026 (7) TMI 280

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....ellant : Shri Bhupendra Shah For the Respondent : Ms. Shababa Parveen, CIT-DR and Shri Swapnil Choudhari (Sr.DR) ORDER PER CHALLA NAGENDRA PRASAD, J.M. These two appeals are filed by the Revenue against the orders of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi ["Ld. CIT(A)"], dated 30.10.2025, for the assessment years 2016-17 and 2018-19. ....

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....2016-17 and A.Y. 2018-19, notices u/s. 148 were issued on 27.07.2022 and 28.04.2022, respectively, which are beyond the period of three years from the end of the relevant assessment years 2016-17 and 2018-19, therefore, the same are bad in law. Ld. Counsel for the assessee placed reliance on the decisions of the Hon'ble Jurisdictional High Court in the case of Mrs. Chitra Supekar vs. ITO, (2023) 4....

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.... of the authorities below and the decisions of the Hon'ble Jurisdictional High Court relied upon. Perusal of the notices issued u/s. 148 and the order passed u/s. 148A(d) of the Act clearly suggests that approval was obtained from the Principal Commissioner of Income Tax beyond the period of three years from the end of the relevant assessment year. The Hon'ble Jurisdictional High Court in the case....