2024 (12) TMI 1791

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....assessment year 2013-14 vide his order dated 28th March, 2022. 2. The only issue in this appeal of the assessee is as regards the order of learned CIT(A) in confirming the action of the Assessing Officer in holding the notice issued under Section 148 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') as legal and consequently framing assessment under Section 147 read with Section 144B of the Act. 3. We have heard both the sides and perused the facts and circumstances of the case. The brief facts are that the assessee filed its original return of income for the relevant assessment year 2013-14 on 14th February, 2014. Subsequently, information was received from Directorate of Income Tax (System) being a potential case fo....

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....ential cases for issue of notice u/s 148 of the Act 'with the approval of CCIT concerned', it is clarified that the CCIT shall call for the list of the potential cases along with details and evidences from the Subordinate Authorities and shall, after careful examination, suggest to the A.O., the potential cases are to be taken for consideration for action u/s 148 of the Act." 5. Learned Counsel then pointed out from Instruction F.No.225/40/2021/ITA-II dated 4th March, 2021 that the assessee's case falls under Clause 1(v) of the Instruction, which reads as under :- "1. The Central Board of Direct Taxes (Board), in exercise of its powers u/s 119 of the Income-tax Act, 1961 (Act), with an objective of streamlining the process of se....