On writ allowing the petition the Court held that notice under section 148 was issued to assessee on 25-6-2019 and prior mandatory approval of Additional dated 26-6-2019. Court held that issue of notice was illegal as there was no prior approval as required under section 151(2) of the Act. Court also observed that it is open to Respondents to take such steps as advised in law and it is open to Petitioner to raise such objections as and when they receive a fresh notice.
River Valley Meadows and Township (P.) Ltd. v. Dy. CIT (2022) 284 Taxman 536 (Bom.)(HC)
S. 148 : Reassessment-Notice-Notice was issued prior approval of Additional Commissioner-Notice was quashed. [S. 147, 151(2), Art. 226]