concerned sanctioning
authority u/s Section 151 as a pre-condition for issuing notice u/s 147 / 148- -Held,
Section 151 stipulates that ... concerned
sanctioning authority u/s Section 151 as a pre-condition for issuing notice
u/s 147 / 148- -Held, Section 151 stipulates that
under
Section 148 of the Act of 1961 could not have been issued.
Remarks of approving authority, as appearing in approval under
Section 151 ... approval/sanction. Section 151 of the Act of 1961 deals with
sanction for issue of notice. Sub-section (2) of Section 151
requires that
under
Section 148 of the Act of 1961 could not have been issued.
Remarks of approving authority, as appearing in approval under
Section 151 ... approval/sanction. Section 151 of the Act of 1961 deals with
sanction for issue of notice. Sub-section (2) of Section 151
requires that
under
Section 148 of the Act of 1961 could not have been issued.
Remarks of approving authority, as appearing in approval under
Section 151 ... approval/sanction. Section 151 of the Act of 1961 deals with
sanction for issue of notice. Sub-section (2) of Section 151
requires that
denial to the fact that notice u/s 148 and approval u/s 151 both are
unsigned.
(ii). The only issue raised by the Deptt ... legal position, the validity of the notice issued u/s 148 and
approval u/s 151 remains intact, notwithstanding the absence of digital
signatures
assessment and
requested to provide copy of the approval of Competent
Authority under section 151 of the I.T. Act, 1961. The
Assessee also contended ... assessment is
barred by time. The assessee further submitted that approval
under section 151 have been granted in a most mechanical
manner without applying independent
assessment is
barred by time. The assessee further submitted that
approval under section 151 have been granted in a most
mechanical manner without applying independent ... mandatory in terms of proviso to sub-
section (1) of section 151 as the action under
section 147 was being initiated after the expiry
given approval under Section
151 of the Act of 1961, which is contrary to the provisions of
Section 151 of the Act of 1961. Hence ... recording his satisfaction as required under Section 151 of the
21
Act of 1961. Provisions under Section 151 (2) of the Act of 1961
mandates
assessment is
barred by time. The assessee further submitted that approval
under section 151 have been granted in a most mechanical
manner without applying independent ... Delhi.
which is mandatory in terms of proviso to sub-
section (1) of section 151 as the action under
section 147 was being initiated after
assessment and
requested to provide copy of the approval of Competent
Authority under section 151 of the I.T. Act, 1961. The
Assessee also contended ... assessment is
barred by time. The assessee further submitted that approval
under section 151 have been granted in a most mechanical
manner without applying independent
