THE HON’BLE THE CHIEF JUSTICE SRI APARESH KUMAR SINGH AND THE HON’BLE SRI JUSTICE G.M.MOHIUDDIN

ORDER:

Sri Hemant Pai, learned counsel appears for Sri S. Pavan Kumar, learned counsel for petitioner.

Smt. Bokaro Sapna Reddy, learned Senior Standing Counsel for Income-tax appears for respondents.

2. A challenge has been made to the notice dated 29.07.2022 issued under Section 148 of the Income-tax Act, 1961 (for short ‘the Act’), for the Assessment Year 2016-17, by respondent No.1, in the present Writ Petition preferred in November, 2025. The petitioner has sought quashing of the assessment order dated 27.04.2023 passed under Section 147 of the Act read with Section 144B of the Act. The petitioner has also assailed the penalty notice dated 27.04.2023 issued Year.

3. The petitioner has also preferred an appeal against the impugned assessment order and the same is pending.

4. Learned counsel for the petitioner has confined the challenge to the issue of sanction accorded by respondent No.3 under Section 151 of the Act and submitted that it is the Principal Chief Commissioner and not the Principal Commissioner of Income Tax-1 empowered to grant sanction for reopening of proceedings issued for