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1 - 10 of 12 (0.24 seconds)Section 69A in The Income Tax Act, 1961 [Entire Act]
Section 151 in The Income Tax Act, 1961 [Entire Act]
Section 147 in The Income Tax Act, 1961 [Entire Act]
The Bankers Books Evidence Act, 1891
Dcit Corporate Circle 1, Coimbatore vs Indo Shell Automotive Systems India ... on 8 September, 2021
7. The above view is confirmed by the Hon'ble Supreme Court in the case
of ITO vs. Prakash Pandurang Patil [2025] 178 taxmann.com 8 (SC) and in
the case of DCIT vs C.E. Info Systems Ltd [2025] 180 taxmann.com 703 (SC).
From the perusal of these facts, we are of the considered view that the ratio
laid down by the judicial precedence is applicable to the present case.
Accordingly respectfully following the above judicial precedence we hold
that the notice issued by the AO u/s.148 beyond 3 years on 07.04.2022 with
the approval of PCIT instead of PCCIT as per the provisions of section 151(ii)
is not valid. Consequently the assessment completed based on the invalid
notice is liable to be quashed.
The Income Tax Act, 1961
Section 151A in The Income Tax Act, 1961 [Entire Act]
Idea Cellular Limited, Indore vs Dcit Tds, Indore on 25 May, 2023
In this regard, we notice that the Hon'ble
Bombay High Court in the case of M/s. Vodafone Idea Limited Vs DCIT (WP
No. 2768 of 2022 dated 06.02.2024) has considered and identical issue and
held that-