Allowing the petition, the Court held that the approval for issuance of notice under section 148 of the Income-tax Act, 1961 ought not to have been obtained from the Additional Commissioner but from the authority specifically mentioned under section 151(ii). The notice issued under section 148 was quashed. Followed J. M. Financial and Investments Consultancy Services (P) Ltd v. ACIT (2023) 451 ITR 205 (Bom)(HC) (AY.2015-16)
MA Multi-Infra Development Pvt. Ltd. v. ACIT (2023)451 ITR 181/149 taxmann.com 491 (Bom.)(HC)
S. 151 : Reassessment – Sanction for issue of notice -Approval obtained from additional Commissioner and not from specified authority — Notice was quashed. [S. 147, 148, 151(ii), Art. 226]