2026 (8) TMI 209

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.... 2. The assessee, an individual and an agent of Hinduja Leyland Finance Limited and Shriram Transport Finance Co. Ltd., for distribution of vehicle loans, did not file the return of income for the assessment year 2018-19 on the reason that his income is within the threshold limit. Based on the information received by the Assessing Officer that there were certain huge cash deposits and withdrawals in the account of the assessee, the Assessing Officer issued a show cause notice under Section 148A(b) of the Income Tax Act, 1961 (in short "the Act") on 21.03.2022, after taking prior approval of the Principal Commissioner of Income Tax (PCIT), Madurai-1. The Assessing Officer passed an order under Section 148A(d) of the Act on 06.04.2022 and ....

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.... still maintainable, since it falls within the exceptions laid down under the said circular. 5. Heard the learned counsel and perused the materials available on record. 6. The Assessing Officer has passed the assessment order stating that order under Section 148A(d) of the Act was passed on 06.04.2022, after taking prior approval of PCIT, Madurai-1. The notice under Section 148 of the Act was issued to the assessee on 07.04.2022. The notice issued pertains to the assessment year 2018-19, which is beyond the period of three years. The ITAT has considered the legal issue as to whether notice can be issued under Section 148 of the Act beyond three years, without obtaining approval from the appropriate authority. 7. The ITAT, placed re....