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| The Tax Publishers2019 TaxPub(DT) 8045 (SC) : (2020) 269 TAXMAN 0195 INCOME TAX ACT, 1961
Section 261 Section 147
Where the department preferred SLP to appeal against the judgment of Bombay High Court in CIT v. Aquatic Remedies (P) Ltd. [ITA No. 904 of 2016, dt. 25-7-2018] : (2018) 406 ITR 545 (Bom) : 2018 TaxPub(DT) 4948 (Bom-HC), whereby the High Court held that it was the CIT who directed the issuance of the notice under section 148 of the AO thus, it was very clear that the final sanction/approval was that of the CIT as indicated in the Form and also in the two letters that the view taken by the Tribunal could not be found fault with as it merely followed the decision of this court in Ghanshyam K Khabrani (2012) 346 ITR 443 (Bom). Therefore, the question as framed did not give rise to any substantial question of law. Supreme Court dismissed the SLP.
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Appeal (Supreme Court) - Special leave petition - Reassessment - Notice under section 148--Validity of notice
Department preferred SLP to appeal against the judgment of Bombay High Court in CIT v. Aquatic Remedies (P) Ltd. [ITA No. 904 of 2016, dt. 25-7-2018] : (2018) 406 ITR 545 (Bom) : 2018 TaxPub(DT) 4948 (Bom-HC), whereby the High Court held that it was the CIT who directed the issuance of the notice under section 148 of the AO thus, it was very clear that the final sanction/approval was that of the CIT as indicated in the Form and also in the two letters that the view taken by the Tribunal could not be found fault with as it merely followed the decision of this court in Ghanshyam K Khabrani (2012) 346 ITR 443 (Bom). Therefore, the question as framed did not give rise to any substantial question of law. Held: The Supreme Court dismissed the SLP.
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