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2024 (5) TMI 447 - DELHI HIGH COURTReopening of assessment u/s 147 - appropriate authority for issuance of the notice - approval of the specified authority u/s 151 - Proceedings after a lapse of more than three years - HELD THAT:- As per Section 151 of the Act and considering the fact that the reopening of the case is occurring after a lapse of more than three years, the appropriate authority for issuance of the notice under Sections 148 and 148A (b) of the Act should have been either the Principal Chief Commissioner or Principal Director General, or in their absence, the Chief Commissioner or Director General, instead of the Principal Commissioner of Income Tax, Delhi-10, who does not fall within the specified authorities outlined in Section 151 of the Act. See TWYLIGHT INFRASTRUCTURE PVT LTD [2024 (1) TMI 759 - DELHI HIGH COURT] Thus we allow the instant writ petition and quash the impugned notices.
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