PCIT Failed To Recorded Satisfaction Under His Signature Prior To Issuance Of Reassessment Notice By AO: Allahabad High Court
Live LawThe Allahabad High Court has held that the Principal Commissioner of Income Tax has not recorded satisfaction under his signature prior to the issuance of a reassessment notice by the Assessing Officer under Section 148 of the Act, 1961. The petitioner/assessee submitted that on the basis of an alleged digital approval under Section 151, the assessing officer issued notices to the assessees under Section 148 of the Act, 1961. Section 151 of the Act, 1961 specifically provides for the recording of satisfaction by the prescribed authority on the reasons recorded by the Assessing Officer that it is a fit case for the issue of a notice under section 148. The digital signature affixed by the PCIT on his satisfaction under Section 151 of the Act, 1961, subsequent to issuance of the notice by the Assessing Officer under Section 148, would not invalidate the notices under Section 148.