The petitioner challenged the notice and order disposing the objection on various grounds one of the ground of challenge was the sanction was obtained by Additional CIT hence the notice is bad in law. According to the Respondents  relied on Taxation and other Laws (Relaxation of Certain Provisions) Act, 2020, by which limitation, inter alia, under provisions of section 151 (1))  and Section 151 (2) which were originally expiring on 31 st march 2020 stood extended to 31 st March 2021. Court held that Relaxation Act provisions cannot be applicable. Even if, the time to issue notice is considered to have been extended, that would not amount to amending the provision of section 151 of the Act.   Allowing the petition the  Court held that the approval ought to have been given by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner and not by the Additional Commissioner of Income Tax.   Notice and order disposal of objection was quashed. Relied on Voltas Ltd. v. ACIT 2022 SCC Online Bom 741. and J.M. Financial and Investment Consultancy Services Pvt. Ltd. v. ACIT, WP No. 1050 of 2022 dt 4-4 2022   (WP No. 43 of 2022, dt.27-4-22) (AY. 2015-2016)

Equitable Financial Consultancy Services Pvt. Ltd. v. ITO (Bom.)(HC) (UR)