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2022 (5) TMI 339 - BOMBAY HIGH COURTValidity of reopening of assessment - rejecting petitioner’s objections to reopening - four years from the end of the relevant assessment year has expired before the issuance of notice - Validity of approval granted by the Additional Commissioner of Income Tax - HELD THAT:- Since four years had expired from the end of the relevant assessment year, as provided under section 151(1) of the Act, it is only the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner who could have accorded the approval and not the Additional Commissioner of Income Tax. On this ground alone, we will have to set aside the notice dated 31.03.2021 issued under section 148 of the Act, which is impugned in this petition. In view thereof, the consequent orders and notices will also have to go. - Decided in favour of assessee.
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