IN THE HIGH COURT OF JUDICATURE AT BOMBAY TRUSHA TUSHAR ORDINARY ORIGINAL CIVIL JURISDICTION MOHITE Digitally signed by TRUSHA TUSHAR MOHITE Date: 2025.08.21 10:52:14 +0530 WRIT PETITION NO. 271 OF 2023 Ramesh Bachulal Mehta .. Petitioner Versus Income Tax Officer Ward-27(3)(1), Mumbai & Ors. .. Respondents Adv. Devendra H. Jain a/w. Adv. Shashank Ajay Mehta i/b. Adv.

Kashyap Chothani for the Applicant.

Adv. Devvrat Singh (through V.C) for the Respondents.

CORAM: B. P. COLABAWALLA &

FIRDOSH P. POONIWALLA, JJ.

DATE: AUGUST 11, 2025 P. C.

1. Rule. Respondents waive service. With the consent of the parties Rule made returnable forthwith and heard finally.

2. The present writ petition inter-alia challenges the notice dated 15.07.2022 issued under section 148 of the Income Tax Act, 1961 (for short the “Act”) for the Assessment Year 2016-17.

3. Among several jurisdictional grounds challenging the re-opening of assessment for the relevant Assessment Year in the present Writ Petition, the Petitioner has inter-alia contended [in Ground B of this petition] that the order passed under section 148A(d) is bad in law because Respondent No.1 has not obtained appropriate prior approval/sanction mandated