Approval to issue Section 148 notice has to be given by JCIT & not by PCIT

Miranda Tools Pvt. Ltd. Vs ITO (Bombay High Court) The Petitioner is a company registered under the Companies Act engaged in the business of manufacture and marketing of fabrics. The Petitioner filed its return of income for the assessment year 2014-15 on 22 September 2014 declaring nil income. The Petitioner’s case was selected for scrutiny assessment vide notice dated 18 September 2015. On 7 April 2016, the Assessing Officer issued notice under section 142(1) of the Income Tax Act, 1961 calling upon the Petitioner to submit certain details regarding share application money received by the ...