2026 (7) TMI 815

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....br>Dated:- 8-7-2026<br>WPT No. 79 of 2024 - -<br>Income Tax<br>HON&#39;BLE SHRI JUSTICE RAKESH MOHAN PANDEY For the Petitioner: Mr. Siddharth Dubey, Advocate. For the Union of India: Mr. Abhishek Banjare, C.G.C. For the Respondents No. 2 to 4: Mr. Ajay Kumarani, Advocate holding the brief of Mr. Amit Chaudhari, Advocate. ORDER 1. The petitioner has assailed a notice issued under Sec....

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....Raipur u/s 148A(a) of the IT Act on 14.02.2024.' He would submit that as approval was granted by the superior authority i.e. CCIT, Raipur and the next step available to the Assessment Officer was to conduct an inquiry under the provisions of Section 148A(a) of the Act of 1961. He would contend that as no inquiry was conducted, and therefore, the notice issued under Section 148A(b) of Act of 1961 a....

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.... that petition is misconceived and deserves to be dismissed. 4. Mr. Abhishek Banjare would support the contention made by Mr. Ajay Kumarani. 5. I have heard learned counsel for the parties and perused the documents placed on record. 6. Section 148A(a) & (b) of Income Tax Act, 1961 read as under :- "148A. Conducting inquiry, providing opportunity before issue of notice under secti....

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.... income chargeable to tax has escaped assessment in his case for the relevant assessment year and results of enquiry conducted, if any, as per clause (a);" 7. Bare reading of provision quoted-above would make it clear that the Assessing Officer before issuing notice under Section 148 of Act of 1961 may conduct an inquiry after obtaining prior approval of specified authority, if required, and th....