The AO issued notice under section 148A(b) on 21-03-2022, order under section 148A(d) and consequent section 148 notice on 07-04-2022, both beyond three years. The sanction was from the Principal Commissioner as provided in section 151(ii). The High Court quashed the proceedings. On SLP, the Supreme Court disposed of the matter in terms of UOI v. Rajeev Bansal (2024) 301 Taxman 238/ 469 ITR 46 (SC). (AY. 2018-19)
ITO v. Pradeep Himatlal Shah (2025) 303 Taxman 166 (SC) Editorial: Pradeep Himatlal Shah v. ITO (2025) 170 taxmann.com 471 (Bom.)(HC)
S. 151 : Reassessment-Sanction for issue of notice-Beyond three years-Approval from Principal Commissioner-SLP covered by UOI v. Rajeev Bansal(2024) 301 Taxman 238/ 469 ITR 46 (SC). [S. 148, 148A(b), 148A(d), 151(ii), Art. 136]
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