No Summon u/s 131(1) Without Pending Proceeding !

The simple answer from various judicial pronouncement is in negative i.e summon can not be issued without pending proceeding under Income Tax Act. However, the provision u/s 131 of the Income Tax Act itself, nowhere mentions such limitation. This is unlike section 133(6) of the Income Tax Act which clearly mentions that if there is no pending proceeding, the Assessing Officer can   seek the information after obtaining permission from the Commissioner of Income Tax. But , similar limitations are not provided under section 131.

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